Also known as: standing doctrines · doctrine of standing · standing · Article III standing
Written by attorneys — see sources below.
A constitutional doctrine requiring a plaintiff to demonstrate an injury in fact that is concrete and particularized, a causal connection between the injury and the defendant's conduct, and a likelihood that a favorable judicial decision will redress the injury. The doctrine enforces the Article III case-or-controversy limitation on federal judicial power and incorporates prudential rules against generalized grievances and third-party claims.
The Cleveland Museum of Art planned an exhibition but faced lender withdrawals after a long-unenforced municipal ordinance resurfaced in public debate. The museum sued the city for declaratory relief asserting injury from the ordinance's existence. The court dismissed for lack of standing because the museum could not show an imminent, concrete injury fairly traceable to city enforcement rather than private decisions.
Steven Silva sued a hospital claiming injury from surgery complications. He alleged the hospital failed to verify the operating physician's credentials. The court dismissed for lack of standing because Silva could not establish that his injury was fairly traceable to the hospital's conduct rather than the physician's independent actions.
Solstice Ventures asserted a security interest in crops grown on a debtor's farm. After default the creditor sued the debtor seeking enforcement. The court dismissed for lack of standing because the creditor failed to demonstrate a concrete, particularized injury redressable by a favorable judicial decision on the security interest.
Samuel Soto used force against an intruder and later sued for damages. He claimed the encounter caused him personal injury. The court dismissed for lack of standing because Soto could not show that any claimed injury satisfied the concrete and particularized requirement needed for Article III standing.
Silverline Industries asserted a security interest in livestock and crops belonging to a farming debtor. After default the bank sued to foreclose. The court dismissed for lack of standing because the bank failed to demonstrate an injury in fact traceable to the debtor's conduct that a favorable decision would redress.
An environmental organization sued a federal agency over a nuclear licensing decision. The court dismissed the complaint because the group failed to show that any member suffered a concrete, particularized injury traceable to the agency's action rather than to generalized policy concerns.
In 1967 the Atomic Energy Commission granted Vermont Yankee a construction permit for a nuclear power plant in Vernon, Vermont, after the required adjudicatory hearing and reviews. Vermont Yankee later applied for an operating license; NRDC intervened and objected to exclusion of fuel-reprocessing and waste-disposal impacts from the hearing. In November 1972 the Commission opened a separate rulemaking proceeding on those fuel-cycle issues, noticed two alternative approaches based on its Environmental Survey, and conducted a February 1973 hearing at which more than forty participants submitted comments but no discovery or cross-examination occurred. In April 1974 the Commission adopted a rule assigning numerical values to fuel-cycle impacts and applied it prospectively. In January 1969 Consumers Power applied for permits to build two nuclear reactors in Midland, Michigan. After staff and ACRS review, Saginaw and Mapleton intervened and raised 119 environmental contentions, including seventeen on energy conservation. The Licensing Board held hearings on radiological issues, the staff issued a final environmental impact statement in March 1972, and further hearings occurred in May and June 1972; Saginaw declined to participate in the later hearings or submit proposed findings. The Licensing Board granted the construction permit, the Appeal Board affirmed, and the Commission declined further review. In November 1973 the Commission ruled in another case that energy-conservation evidence meeting threshold tests could be considered, but it later refused Saginaw's motion to reopen the Consumers Power record. NRDC appealed the Vermont Yankee license and rule to the D.C. Circuit; Saginaw and others appealed the Consumers Power permit. In 1976 the Court of Appeals remanded both matters, holding the fuel-cycle rulemaking procedures inadequate, the Consumers Power environmental impact statement defective for omitting energy conservation, and the ACRS report insufficiently explained. The Supreme Court granted certiorari in 1977. The Commission is the successor agency to the Atomic Energy Commission under the Energy Reorganization Act of 1974. All licensing proceedings followed the two-stage process of construction permit followed by operating license under the Atomic Energy Act of 1954, with NEPA environmental reviews added after 1969.
View caseA plaintiff must show an injury in fact that is concrete and particularized, causation fairly traceable to the defendant's conduct, and a likelihood that a favorable decision will redress the injury. These requirements derive directly from Article III's case-or-controversy limitation.
Yes. The doctrine prohibits adjudication of abstract or widely shared grievances more appropriately addressed by the political branches. A plaintiff must allege a personal stake rather than harm shared equally by all citizens.
Ordinarily a plaintiff may not raise the legal rights of others. Exceptions exist when substantial obstacles prevent the third party from asserting its own rights and when the plaintiff has a close relationship with the third party.
Standing focuses on whether the plaintiff has a sufficient personal stake at the time suit is filed. Ripeness concerns whether a dispute is sufficiently developed for judicial review, while mootness asks whether an actual controversy persists throughout the litigation.
…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…