MY NOTES: Business Organizations | Constitutional Law I | Copyright Law | Evidence | Wills and Trusts

Lujan v. Defenders of Wildlife, 504 U.S. 555 (1992)




Environmental groups brought action challenging regulation of the Secretary of the Interior which required other agencies to confer with him under the Endangered Species Act only with respect to federally funded projects in the United States and on the high seas.

Injuries complained of by plaintiffs: would not be able to see endangered animals next time they traveled to the area


The United States District Court for the District of Minnesota, dismissed for lack of standing. The Court of Appeals for the Eighth Circuit reversed. The District Court entered judgment in favor of environmental groups, and the Court of Appeals affirmed.


Respondents, wildlife conservation and other environmental organizations, filed an action in the District Court, seeking a declaratory judgment that the new regulation erred as to 7(a)(2)'s geographic scope and an injunction requiring the Secretary of the Interior to promulgate a new rule restoring his initial interpretation.

Defendant moved for summary judgment for lack of standing.


There must be injury in fact, a causal connection between the injury complained of and the conduct complained of, and it must be likely as opposed to merely speculative that the injury will be redressed by a favorable decision.


HELD: (1) plaintiffs did not assert sufficiently imminent injury to have standing, and (2) plaintiffs' claimed injury was not redressable.


Standing is not an ingenious academic exercise in the conceivable, but as we have said requires, at the summary judgment stage, a factual showing of perceptible harm.


Elements necessary for standing

  1. Injury in fact
  2. Causal connection between injury and conduct complained of
  3. Likely as opposed to merely speculative that the injury will be redressed by a favorable decision