Lujan v. Defenders of Wildlife

Following is the case brief for Lujan v. Defenders of Wildlife, 504 U.S. 555 (1992)

Case Summary of Lujan v. Defenders of Wildlife:

  • The Secretary of the Interior changed the geographic scope of the Endangered Species Act to only include activities in the United States and the high seas.
  • Several environmental groups sued to have the old geographic scope reinstated.
  • The District Court initially dismissed the suit based on standing, but ultimately, the Eighth Circuit Court of Appeals agreed with respondents’ request for relief.
  • The U.S. Supreme Court reversed and remanded the Eighth Circuit’s decision.  The Court held that standing requires “injury in fact,” and therefore the environmental groups lacked standing to sue.

Lujan v. Defenders of Wildlife Case Brief

Statement of the Facts:

The Endangered Species Act of 1973 requires that agencies consult with the Secretary of the Interior to ensure that any action funded by an agency will not likely jeopardize a habitat or any endangered species.  A later regulation under the Act limited the Act’s geographic scope to just the United States and the high seas.

The respondents, Defenders of Wildlife and other organizations, sought a declaration in District Court that the regulation limiting the geographic scope was incorrect, and sought an order that the Secretary of the Interior restore the old geographic scope.

Procedural History:

  • The District Court dismissed the suit for lack of standing.
  • The Eighth Circuit Court of Appeals reversed.
  • On remand, the District Court denied the government’s renewed standing argument, and granted summary judgment to respondents.
  • The Court of Appeals affirmed.
  • The U.S. Supreme Court granted certiorari.

Issue and Holding:

Do environmental groups lack standing to challenge a rule change by the Department of the Interior on the geographic scope of an environmental law, because they did not suffer an injury to a legally protected interest?  Yes.

Judgment:

The decision of the Eighth Circuit Court of Appeals is reversed and remanded.

Rule of Law or Legal Principle Applied:

Environmental groups that are not directly impacted by an agency’s rule change do not have standing to seek judicial review of that rule.

Reasoning:

Any party invoking federal jurisdiction must prove that it has standing based on an injury in fact or imminent invasion of a legally protected interest.  Here, the environmental groups in question are not the object of the agency’s rule, and therefore lack the requisite standing to sue.

Further, evidence that group members would visit the relevant geographic areas at some time in the future, or other novel standing theories – such as the notion that all people are part of a contiguous ecosystem – are not persuasive.  The injuries the respondents raise are speculative in nature.

Finally, a plurality of the Court also agreed that the respondents also have a road-block in their suit with regard to redressability.  The “citizen-suit” provision in the Endangered Species Act does not confer on all citizens the right to redress a perceived agency failure.  Congress and the Chief Executive have the responsibility to see that laws are faithfully executed.  That responsibility cannot be transferred to citizens with only a general grievance of policy, and no concrete injury.

Concurring and Dissenting Opinions:

Concurring Opinion (Kennedy):

The majority is correct that respondents have failed to demonstrate injury such that they would have standing to sue.  Nor can the respondents establish standing based on an “ecosystem nexus” or something similar, at least on the facts in this case.  Finally, the Court did not need to reach the issue of redressability.

Concurring in the Judgment (Stevens):

Congress did not intend the consultation requirement in the Endangered Species Act to apply to actions in foreign countries, therefore the Court’s judgment is correct.  However, the Court’s conclusion on standing and redressability are not correct.  An interest in preservation, research, or even observation is enough to confer standing, and the plurality’s reasoning on redressability is not persuasive.

Dissenting Opinion (Blackmun):

The respondents raised enough issues of fact to survive summary judgment on injury and redressability.  Also, the Court goes too far in rejecting standing for “procedural” injuries.  Judicial limitations should not be imposed on Congress’ authority to allow citizen suits in this context.

Significance:

Lujan v. Defenders of Wildlife is significant because it limits standing so dramatically, requiring a concrete “injury in fact” to establish standing to challenge a government agency’s rule.  At the time it was decided, the case was a blow to progressive groups concerned about the environment.

Student Resources:

Read the Full Court Opinion

Listen to the Oral Arguments

 

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