Law School Case Brief
Lujan v. Defs. 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."
Petitioner Manuel Lujan, the Secretary of the Interior, promulgated a new interpretation § 7 of the Endangered Species Act of 1973 (Act), which required consultation only for actions taken in the United States or on the high seas. Respondent Defenders of Wildlife filed suit seeking declaratory judgment and injunctive relief to restore Lujans's initial interpretation. The district court granted Lujan's motion to dismiss for lack of standing but on appeal, the circuit court reversed.
Did the Defenders of Wild Life have standing to bring an action?
The circuit court's decision was reversed and remanded. The Court reasoned that respondent lacked standing under Article III of the Constitution to bring an action, as respondent failed to establish all three prongs required for standing. The burden of proof was not met regarding causation and redressability of respondent's injury. Therefore, petitioner's motion for summary judgment should have been granted.
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