Lujan v. Defenders of Wildlife, 504 U.S. 555 (1992), was a landmark Supreme Court of the United States decision, handed down on June 12, 1992, that heightened standing requirements under Article III of the United States Constitution. It is "one of the most influential cases in modern environmental standing jurisprudence."[1] Lily Henning of the Legal Times stated that:
112 S. Ct. 2130; 119 L. Ed. 2d 351; 60 U.S.L.W. 4495; 1992 U.S. LEXIS 3543; 34 ERC (BNA) 1785; 92 Cal. Daily Op. Service 4985; 92 Daily Journal DAR 7876; 92 Daily Journal DAR 8967; 22 ELR 20913; 6 Fla. L. Weekly Fed. S 374
Case history
Prior
Defendant's motion to dismiss granted, Defenders of Wildlife v. Hodel, 658 F. Supp. 43 (D. Minn. 1987); reversed and remanded, 851 F.2d 1035 (8th Cir. 1988); summary judgment granted to plaintiffs, 707 F. Supp. 1082 (D. Minn. 1988); affirmed, sub nom.Defenders of Wildlife v. Lujan, 911 F.2d 117 (8th Cir. 1988); cert. granted, 500 U.S. 915 (1991)
Holding
Plaintiffs did not have standing to bring suit under the Endangered Species Act, because the threat of a species' extinction alone did not establish an individual and nonspeculative private injury.
In [this] decision, hailed by the right and attacked by the left as well as by a broad swath of legal scholars, the Court made clear that plaintiffs must suffer a concrete, discernible injury—not a "conjectural or hypothetical one"—to be able to bring suit in federal court. It, in effect, made it more difficult for plaintiffs to challenge the actions of a government agency when the actions don't directly affect them.[2]
In Scalia's interpretation of Article III of the Constitution, plaintiffs must demonstrate that they have suffered an injury in fact, caused by the defendant, which a favorable court decision could redress, to meet the standing requirement to bring a case before the court.[3] In his opinion for the majority, Justice Scalia stated that Defenders had failed to satisfy the “injury in fact” element.[4] He wrote that the Court rejected the view that the citizen suit provision of the statute conferred upon “all persons an abstract, self-contained, non-instrumental ‘right’ to have the Executive observe the procedures required by law."[5] Rather, he explained, an American citizen plaintiff must have suffered a tangible and particular harm.[6]
Additionally, in the portion of his opinion that garnered only plurality support, Justice Scalia determined that the plaintiffs failed to demonstrate the redressability element.[7]
In his opinion concurring in part, Justice Anthony Kennedy, joined by Justice David Souter, asserted that an airline ticket to the affected geographic areas with endangered species in question would have been enough to satisfy the imminent threat of future injury requirement.[8]
Justice John Paul Stevens concurred in the judgement as well, but disagreed with the Court's finding that Defenders lacked standing.[9] Justice Stevens instead rested his opinion on a statutory construction of the Endangered Species Act.[10]
^"Lujan v. Defenders of Wildlife—Can Environmental Litigants Regain Ground to Stand on Using the "Ecosystem Nexus" Test for Causation, Redressibility?". Vermont Law Review. 2015-03-29. Retrieved 2021-12-07.
^ Henning, Lily. "Roberts and Scalia: Standing Side by Side". law.com. Retrieved 2012-07-20.(subscription required)
Works related to Lujan v. Defenders of Wildlife at Wikisource
Text of Lujan v. Defenders of Wildlife, 504U.S. 555 (1992) is available from:CourtListenerFindlawGoogle ScholarJustiaOpenJuristOyez (oral argument audio)
Full Text of Volume 504 of the United States Reports at www.supremecourt.gov
July 31, 2023
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Lujan v Defenders of Wildlife 504 U S 555 1992 was a landmark Supreme Court of the United States decision handed down on June 12 1992 that heightened standing requirements under Article III of the United States Constitution It is one of the most influential cases in modern environmental standing jurisprudence 1 Lily Henning of the Legal Times stated that Lujan v Defenders of WildlifeSupreme Court of the United StatesArgued December 3 1991Decided June 7 1992Full case nameManuel Lujan Jr Secretary of the Interior Petitioner v Defenders of Wildlife et al Citations504 U S 555 more 112 S Ct 2130 119 L Ed 2d 351 60 U S L W 4495 1992 U S LEXIS 3543 34 ERC BNA 1785 92 Cal Daily Op Service 4985 92 Daily Journal DAR 7876 92 Daily Journal DAR 8967 22 ELR 20913 6 Fla L Weekly Fed S 374Case historyPriorDefendant s motion to dismiss granted Defenders of Wildlife v Hodel 658 F Supp 43 D Minn 1987 reversed and remanded 851 F 2d 1035 8th Cir 1988 summary judgment granted to plaintiffs 707 F Supp 1082 D Minn 1988 affirmed sub nom Defenders of Wildlife v Lujan 911 F 2d 117 8th Cir 1988 cert granted 500 U S 915 1991 HoldingPlaintiffs did not have standing to bring suit under the Endangered Species Act because the threat of a species extinction alone did not establish an individual and nonspeculative private injury Court membershipChief Justice William Rehnquist Associate Justices Byron White Harry BlackmunJohn P Stevens Sandra Day O ConnorAntonin Scalia Anthony KennedyDavid Souter Clarence ThomasCase opinionsMajorityScalia Parts I II III A IV joined by Rehnquist White Kennedy Souter ThomasPluralityScalia Part III B joined by Rehnquist White ThomasConcurrenceKennedy joined by SouterConcurrenceStevensDissentBlackmun joined by O ConnorLaws appliedU S Const Art III 16 U S C 1536 7 of the Endangered Species Act of 1973 In this decision hailed by the right and attacked by the left as well as by a broad swath of legal scholars the Court made clear that plaintiffs must suffer a concrete discernible injury not a conjectural or hypothetical one to be able to bring suit in federal court It in effect made it more difficult for plaintiffs to challenge the actions of a government agency when the actions don t directly affect them 2 In Lujan the Court held that a group of American wildlife conservation and other environmental organizations lacked standing to challenge regulations jointly issued by the U S Secretaries of the Interior and Commerce regarding the geographic area to which a particular section of the Endangered Species Act of 1973 applied The case arose over issues of US funding of development projects in Aswan Egypt and Mahaweli Sri Lanka that could harm endangered species in the affected areas The government declared that the act did not apply to projects outside of the United States and Defenders of Wildlife sued Contents 1 Opinion 2 See also 3 References 4 External linksOpinion EditIn Scalia s interpretation of Article III of the Constitution plaintiffs must demonstrate that they have suffered an injury in fact caused by the defendant which a favorable court decision could redress to meet the standing requirement to bring a case before the court 3 In his opinion for the majority Justice Scalia stated that Defenders had failed to satisfy the injury in fact element 4 He wrote that the Court rejected the view that the citizen suit provision of the statute conferred upon all persons an abstract self contained non instrumental right to have the Executive observe the procedures required by law 5 Rather he explained an American citizen plaintiff must have suffered a tangible and particular harm 6 Additionally in the portion of his opinion that garnered only plurality support Justice Scalia determined that the plaintiffs failed to demonstrate the redressability element 7 In his opinion concurring in part Justice Anthony Kennedy joined by Justice David Souter asserted that an airline ticket to the affected geographic areas with endangered species in question would have been enough to satisfy the imminent threat of future injury requirement 8 Justice John Paul Stevens concurred in the judgement as well but disagreed with the Court s finding that Defenders lacked standing 9 Justice Stevens instead rested his opinion on a statutory construction of the Endangered Species Act 10 See also EditList of United States Supreme Court cases volume 504 List of United States Supreme Court cases Lists of United States Supreme Court cases by volume List of United States Supreme Court cases by the Rehnquist CourtReferences Edit Lujan v Defenders of Wildlife Can Environmental Litigants Regain Ground to Stand on Using the Ecosystem Nexus Test for Causation Redressibility Vermont Law Review 2015 03 29 Retrieved 2021 12 07 Henning Lily Roberts and Scalia Standing Side by Side law com Retrieved 2012 07 20 subscription required Lujan 504 U S at 560 61 Lujan 504 U S at 562 Lujan 504 U S at 573 Lujan 504 U S at 574 Lujan 504 U S at 568 Lujan 504 U S at 578 80 Lujan 504 U S at 582 Lujan 504 U S at 586 External links Edit Works related to Lujan v Defenders of Wildlife at Wikisource Text of Lujan v Defenders of Wildlife 504 U S 555 1992 is available from CourtListener Findlaw Google Scholar Justia OpenJurist Oyez oral argument audio Case Brief for Lujan v Defenders of Wildlife at Lawnix com Full Text of Volume 504 of the United States Reports at www supremecourt gov Retrieved from https en wikipedia org w index php title Lujan v Defenders of Wildlife amp oldid 1160978387, wikipedia, wiki, book, books, library,
