Sierra Club v. Morton

Supreme Court of the United States · 1972 · Federal Courts

405 U.S. 727 (1972)

Updated August 1, 2026

Federal Courtsorganizational standingstandingAPAinjury in factenvironmental standingaesthetic injuryrecreational injury

Facts

The Forest Service approved a large Disney ski-resort development in Mineral King Valley, and related highway and power-line proposals required approval from the Department of the Interior because they would cross Sequoia National Park. The Sierra Club opposed the project and sued under the Administrative Procedure Act, alleging that the project would harm the scenery, wildlife, and enjoyment of the area and violate federal laws and regulations governing parks, forests, and game refuges. In its complaint, the Club alleged that it was a membership corporation with a special interest in conservation and that its interests would be affected, but it did not allege that the Club or any of its members used Mineral King or Sequoia National Park or would be affected in their activities or pastimes by the development.

Issue

Whether the Sierra Club alleged facts sufficient to obtain judicial review under § 10 of the Administrative Procedure Act. More specifically, the question was whether an organization has standing based solely on its longstanding interest and expertise in environmental conservation, without alleging that it or its members are themselves among those injured by the challenged action.

Rule

Under APA § 702, a plaintiff has standing to seek judicial review when it alleges injury in fact to an interest arguably within the zone of interests protected or regulated by the relevant statute. Aesthetic and environmental harm can qualify as injury in fact, but the plaintiff must allege facts showing that it or its members are themselves among the injured; a mere special interest in the subject matter or an organizational interest in a problem is not enough.

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

Prairie Habitat Alliance, a nonprofit based in Omaha, files suit in federal court to challenge a federal agency's approval of a visitor complex near a protected wetland in Nebraska. Its complaint alleges that the group has spent decades advocating bird conservation and that the project will damage habitat and scenic values, but it does not allege that the organization or any member uses the wetland.

Under the majority's standing analysis, is the organization likely to have standing?

Explanation. The majority held that APA § 702 requires injury in fact to the plaintiff, not just a cognizable environmental concern. Aesthetic and environmental harms can qualify, but the plaintiff must allege that it or its members are among those injured. A mere organizational interest in the problem, however longstanding, is not enough.