Also known as: standing principle · principles of standing · standing · doctrine of standing · locus standi
Written by attorneys — see sources below.
A procedural requirement that limits access to federal courts by demanding that a litigant demonstrate a concrete and particularized injury fairly traceable to the challenged conduct and redressable by a favorable judicial decision.
Phuong Pham was convicted after a jury rejected her insanity defense. She appealed, arguing that her inability to control her actions due to mental illness should have produced an acquittal. The appellate court dismissed the appeal for lack of standing because Phuong had already been convicted and could not show a redressable injury from the trial court's application of the traditional test.
Pierre Poulin sued a surgeon for malpractice after a procedure performed in a small community hospital. The complaint alleged that the surgeon failed to meet the skill level of specialists in major cities. The court dismissed for lack of standing, holding that Pierre could not establish an injury traceable to any deviation from the community standard of care.
Premier Manufacturing claimed a security interest in software embedded in factory equipment sold to a debtor. When the debtor filed bankruptcy, Premier sought a declaration that the software qualified as goods. The bankruptcy court denied standing because Premier could not demonstrate a concrete injury from the classification that a favorable ruling would redress.
Pierce Patterson sought a declaratory judgment that he could use deadly force against an intruder who posed only a minor threat. The court dismissed the action for lack of standing, finding that Pierce had not suffered an actual injury and that any ruling would amount to an advisory opinion on the meaning of serious bodily harm.
Progressive Healthcare asserted a security interest in livestock raised by a borrower engaged in farming. After default, the lender asked the court to classify the animals as farm products rather than equipment. The court held that Progressive lacked standing because it could not show a particularized injury traceable to the classification that judicial relief would remedy.
Prism Analytics and several members sued federal agencies over a regulation that allegedly threatened endangered species abroad. The plaintiffs alleged only a general interest in wildlife preservation. The Supreme Court held that the plaintiffs lacked standing because they failed to show imminent, concrete injury to themselves that a favorable decision would redress.
In 1973 Congress enacted the Endangered Species Act to protect species of animals against threats to their continuing existence caused by man. In 1978 the Fish and Wildlife Service and National Marine Fisheries Service issued a joint regulation interpreting section 7(a)(2) to require federal agencies to consult with the Secretary of the Interior on actions taken in foreign nations. In 1986 the Secretary promulgated a revised regulation that limited the consultation obligation to actions within the United States or on the high seas. Shortly after the 1986 regulation took effect, Defenders of Wildlife and other environmental organizations filed suit in the United States District Court for the District of Minnesota against the Secretary of the Interior. The complaint sought a declaratory judgment that the regulation was invalid as to its geographic scope and an injunction requiring the Secretary to promulgate a new regulation mandating consultation for foreign projects. The complaint alleged that the absence of consultation would increase the rate of extinction of endangered and threatened species. The complaint further alleged that some of the organizations' members observed these species both domestically and abroad. Respondents supported their allegations with affidavits from two members. Joyce Kelly stated that she had traveled to Egypt in 1986, observed the habitat of the endangered Nile crocodile, and intended to return. Kelly further stated that she would suffer harm from the United States role in the rehabilitation of the Aswan High Dam. Amy Skilbred stated that she had traveled to Sri Lanka in 1981, observed the habitat of endangered species including the Asian elephant and leopard at the site of the Mahaweli project funded by the Agency for International Development, and intended to return. Skilbred admitted she had no current plans to return because of a civil war. The District Court dismissed the complaint for lack of standing. The Court of Appeals for the Eighth Circuit reversed. On remand the District Court denied the Secretary's motion for summary judgment on standing. The District Court granted respondents' motion for summary judgment on the merits and enjoined the Secretary from applying the regulation to foreign countries. The Eighth Circuit affirmed. The Supreme Court granted certiorari.
View caseA plaintiff must demonstrate an injury in fact that is concrete and particularized, fairly traceable to the defendant's conduct, and likely to be redressed by a favorable decision.
No. A plaintiff must show a concrete and imminent injury to itself rather than a mere abstract concern about environmental harm.
Standing requires a redressable injury. Once convicted, a defendant ordinarily cannot obtain standing to relitigate the application of the M'Naghten test on appeal.
…District Court for the Northern District of Texas, to which the action was referred, held that the Does and Hallford had no standing to sue, but that Roe did have standing, and that the Texas abortion laws were unconstitutional. The court declared the laws void but refused to issue an injunction against their…