Steel Co. v. Citizens for a Better Env't - 523 U.S. 83, 118 S. Ct. 1003 (1998)

Rule:

The irreducible constitutional minimum of standing contains three requirements. First and foremost, there must be alleged (and ultimately proven) an injury in fact -- a harm suffered by the plaintiff that is concrete and actual or imminent, not conjectural or hypothetical. Second, there must be causation -- a fairly traceable connection between the plaintiff's injury and the complained-of conduct of the defendant. And third, there must be redressability -- a likelihood that the requested relief will redress the alleged injury. This triad of injury in fact, causation, and redressability comprises the core of U.S. Const. art. III's case-or-controversy requirement, and the party invoking federal jurisdiction bears the burden of establishing its existence.

Facts:

Alleging that petitioner Steel Company had violated the Emergency Planning and Community Right-To-Know Act of 1986 (EPCRA) by failing to file timely toxic- and hazardous-chemical storage and emission reports for past years, respondent Citizens for a Better Environment filed the present private enforcement action for declaratory and injunctive relief under EPCRA's citizen-suit provision, 42 U.S.C. § 11046(a)(1). The District Court held that, because petitioner had brought its filings up to date by the time the complaint was filed, the court lacked jurisdiction to entertain a suit for a present violation; and that, because EPCRA did not allow suit for a purely historical violation, respondent's allegation of untimely filing was not a claim upon which relief could be granted. The Seventh Circuit reversed, concluding that EPCRA authorized citizen suits for purely past violations. Petitioner challenged the decision. 

Issue:

Due to the fact that petitioner had brought its filings up to date by the time the complaint was filed, should the complaint be dismissed for respondent’s lack of standing to maintain the same? 

Answer:

Yes.

Conclusion:

On review, the Court held that the requirement that jurisdiction be established as a threshold matter arose from the nature and limits of the judicial power of the United States under U.S. Const. art. III, § 2, and was inflexible and without exception. The Court rejected the practice of assuming jurisdiction for the purpose of deciding a case's merits. The Court held that the respondent failed to meet the redressability requirement of standing because none of the relief sought served to compensate the respondent for losses caused by the petitioner's late reporting or to eliminate any effects of that late reporting. The civil penalties authorized under 42 U.S.C.S. § 11045(c) were not payable to the respondent but rather to the United States Treasury, and psychic satisfaction with the results of a lawsuit was not an acceptable U.S. Const. art. III remedy because it did not redress a cognizable injury. Nor could the respondent achieve standing by relying on 42 U.S.C.S. § 11046(f), which authorized reimbursement of the costs of bringing suit. Further, the injunctive relief sought to deter future violations was not redress for past infractions and was insufficient for purposes of Article III.