Friday, February 1, 2013

Lujan v. Defenders of Wildlife case brief

Lujan v. Defenders of Wildlife case summary
504 U.S. 555

PROCEDURAL HISTORY: Appeal on writ of certiorari from a judgment of the United States Court of Appeals for Eighth Circuit, which reversed a lower court's grant of petitioner Secretary of the Interior's motion to dismiss respondent wildlife organizations' action for declaratory relief under § 7(a) of the Endangered Species Act of 1973, 16 U.S.C.S. § 1536(a)(2).

-Petitioner, the Secretary of the Interior, promulgated a new interpretation § 7 of the Endangered Species Act of 1973 (Act), 16 U.S.C.S. § 1536(a)(2), which required consultation only for actions taken in the United States or on the high seas.
-Respondents, wildlife conservation organizations, filed suit seeking declaratory judgment and injunctive relief to restore petitioner's initial interpretation.
-The district court granted petitioner's motion to dismiss for lack of standing, but the circuit court reversed.
-The Supreme Court held that respondents lacked standing under Article III of the Constitution to bring an action, as respondents failed to establish all three prongs required for standing.
-The burden of proof was not met regarding causation and redressability of respondents' injury.
-Therefore, petitioner's motion for summary judgment should have been granted.

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."

CONCLUSION: Judgment was reversed and remanded because respondents lacked standing to bring the action.

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