An association has standing to bring suit on behalf of its members when its members would otherwise have standing to sue in their own right, the interests it seeks to protect are germane to the organization's purpose, and neither the claim asserted nor the relief requested requires the participation of individual members in the lawsuit.
Appellant state enacted N.C. Gen. Stat. § 106-189.1, prohibiting closed containers of apples shipped into the state from displaying state grades or classifications. Appellee, a statutory agency for the promotion and protection of the Washington State apple industry, sued, asserting that the statute violated the Commerce Clause and seeking injunctive relief from its enforcement. The district court granted the requested relief. On review, the Court affirmed.
Does Appellee have judicial standing to file a suit?
Appellee had standing to sue because it performed the functions of a traditional trade association representing the state apple industry. The association clearly sought relief, which will inure to the benefit of those members of the association actually injured.