Home › Case briefs › Constitutional Law

Lujan v. Defenders of Wildlife

Supreme Court of the United States · 1992 · Constitutional Law

standinginjury in factcausationredressabilityArticle IIIArticle IIIstandinginjury in fact

Facts

The Secretary of the Interior promulgated a regulation interpreting ESA § 7(a)(2) consultation requirements to apply only to agency actions in the United States or on the high seas, not in foreign countries. Respondents sought declaratory and injunctive relief requiring the Secretary to restore the earlier interpretation that had extended consultation to actions abroad. To establish standing at summary judgment, respondents relied primarily on affidavits from two members who had previously visited habitats in Egypt and Sri Lanka and stated that they intended to return someday to observe endangered species there. Respondents also invoked the ESA citizen-suit provision and argued that the failure to require consultation itself created a procedural injury.

Issue

Whether respondents had Article III standing to challenge the Secretary's regulation limiting ESA § 7 consultation to domestic actions and the high seas. Specifically, did they show injury in fact and redressability, or could the ESA citizen-suit provision confer standing based on a procedural right to consultation alone?

Rule

The irreducible constitutional minimum of standing contains three elements: (1) injury in fact, meaning an invasion of a legally protected interest that is concrete and particularized and actual or imminent, not conjectural or hypothetical; (2) causation, meaning the injury is fairly traceable to the challenged action of the defendant and not the result of independent action of a third party not before the court; and (3) redressability, meaning it is likely, not merely speculative, that the injury will be redressed by a favorable decision. At the summary judgment stage, the plaintiff must set forth specific facts supporting each element. Congress may not convert a generalized public interest in executive compliance with law into an individual right sufficient for Article III standing without a concrete injury.

🔒

See the holding & full analysis

Create a free KwikCourt account to unlock the rest of this brief — and practice the case.

The court's holding and reasoning
Doctrine tests, pitfalls & exam hypotheticals
10 practice questions + 4 AI-graded essays on this case

Free sample · practice this case

Test yourself

One of 10 multiple-choice questions for this case. Pick an answer to see why.

Maya Chen belongs to a conservation group in Seattle. She submitted an affidavit stating that she visited a rainforest in Belize four years ago, hopes to return "when work calms down," and wants to challenge a federal regulation that allegedly allows agency-backed road projects there to threaten rare parrots she wishes to photograph.

At summary judgment, which is the strongest argument that Maya lacks Article III standing?

Explanation. Standing requires a concrete and particularized injury that is actual or imminent, not conjectural or hypothetical. At summary judgment, the plaintiff must set forth specific facts. A vague intention to revisit a place "someday" is insufficient to establish imminent injury, even if observing wildlife is a cognizable interest.