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Law School Case Brief

Lujan v. Defenders of Wildlife - 504 U.S. 555, 112 S. Ct. 2130 (1992)


The irreducible constitutional minimum of standing contains three elements. First, the plaintiff must have suffered an "injury in fact," an invasion of a legally protected interest which is (a) concrete and particularized, and (b) actual or imminent, not "conjectural" or "hypothetical." Second, there must be a causal connection between the injury and the conduct complained of, the injury has to be fairly traceable to the challenged action of the defendant, and not the result of the independent action of some third party not before the court. Third, it must be "likely," as opposed to merely "speculative," that the injury will be "redressed by a favorable decision." 


Section 7(a)(2) of the Endangered Species Act (ESA) requires each federal agency to consult with the United States Secretary of the Interior to insure that any action authorized, funded, or carried out by such agency is not likely to jeopardize the continued existence of any endangered or threatened species. In 1978, the Fish and Wildlife Service and the National Marine Fisheries Service, on behalf of the Secretary of the Interior and the Secretary of Commerce respectively, promulgated a joint regulation stating that the obligations imposed by 7(a)(2) extended to actions taken in foreign nations. However, a revised joint regulation, promulgated in 1986, reinterpreted 7(a)(2) to require consultation only for actions taken in the United States or on the high seas. Organizations dedicated to wildlife conservation and other environmental causes filed an action against the Secretary of the Interior in the United States District Court for the District of Minnesota to seek (1) a declaratory judgment that the regulation was in error as to the geographical scope of 7(a)(2), and (2) an injunction requiring the Secretary to promulgate a new regulation restoring the initial interpretation. The District Court granted the Secretary's motion to dismiss for lack of standing.


Did respondents lack standing under Article III of the Constitution to bring an action?




The United States Supreme Court ruled that the circuit court's decision should be reversed and remanded because the Court reasoned that respondents lacked standing under Article III of the Constitution to bring an action, as respondents failed to establish all three prongs required for standing. The burden of proof was not met regarding causation and redressability of respondents' injury. Therefore, petitioner's motion for summary judgment should have been granted.

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