Saturday, May 17, 2014

Lujan v. Defenders of Wildlife case brief

Lujan v. Defenders of Wildlife case brief summary
Full Text of Case: Lujan v. Defenders of Wildlife - 504 U.S. 555 (1992)

The Secretary of Interior promulgated a rule which interpreted Section:7 of the Endangered Species Act as applicable only to actions within the United States or on the high seas. The Defenders of Wildlife brought a challenge to the above rule.  The District Court granted summary judgment against the Defenders of Wildlife for lack of standing.

FACTSRespondents filed this action against the Secretary of the Interior seeking a declaratory judgment that the new regulation was in error as to the scope of Section:7(a)(2) of the Act, and sought an injunction which would require the Secretary to promulgate a new regulation restoring its initial interpretation that the obligations imposed by the section extended to actions taken in foreign nations.

The District Court granted the Secretary’s motion to dismiss for lack of standing.  The Court of Appeals reversed the District Court's holding and remanded. On remand, the District Court denied the Secretary’s motion for summary judgment and ordered the Secretary to publish a revised regulation. The Court of Appeals then affirmed the District Court. 

RULESUnder Article III, Section:1 of the United States Constitution, jurisdiction of federal courts is limited to “cases” and “controversies."  This is known as the doctrine of standing. To have standing, a plaintiff must have an injury-in-fact.  An injury-in-fact means that there must be a causal connection between the injury and the conduct complained of; and it must be likely, rather than speculative, that the injury will be redressable by a favorable court decision.

ISSUE Did the Respondents have standing to seek judicial review of the rule? 

HOLDINGNo, the respondents did not have standing to seek juridical review of the rule.

  • The Court of Appeals failed to apply the proper principles of standing. 
  • The respondents had not made the requisite demonstration of at least injury and redressability. 
  • The affidavits of two female members that was submitted by the Respondents contained no facts showing how damage to the species would produce “imminent” injury. 
  •  The women “had visited” Egypt in the past, and hoped to visit again “some day.” 
  • That was too insufficient to support an injury-in-fact. 
  • The agencies that were funding the projects were not parties to the case, therefore the Court could only afford relief against the Secretary. 
  • This would only remedy Respondents’ alleged injury if the funding agencies were bound by the Secretary’s regulations, however this was questionable. 
  • A further impediment to redressability was that the agencies generally supplied only a fraction of the funding for a foreign project, and Respondents did not produce anything to indicate that the projects that were named would be suspended or would do less harm to the species without that fractional contribution. 

The party that invokes federal jurisdiction has the burden of proof with respect to standing, and the respondents in this case failed to provide sufficient proof of injury or redressability.

The Respondents raised genuine issues of fact as to injury and redressability, sufficient to survive summary judgment. The Court was overly broad in rejecting standing for “procedural injuries.”  

Justices Kennedy and Souter agreed with the result, however, they wrote to make several observations. Since the Court concluded that the respondents had not demonstrated a concrete injury, they would not have reached the issue of redressability. Also, Congress has the power to define injuries and articulate chains of causation, but congress must at least identify the injury and class of persons that are entitled to bring suit. The citizen-suit provision of the Act did not meet these minimal requirements.

Justice Stevens, who concurring in the judgment, disagreed with the Court’s conclusion that respondents lacked standing because the threatened injury to their interest in protecting the environment was not “imminent.” Furthermore, Stevens also disagreed that the injury was not redressable.

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