Facts of the case
The Endangered Species Act of 1973 (S7(a)(2)) required federal agencies to consult with the Secretary of the Interior to ensure that any authorized actions did not jeopardize endangered or threatened species or critically destroy natural habitats. A 1986 amendment to the act limited it scope to actions in the United States or on the high seas. Defenders of Wildlife and other organizations dedicated to wildlife conservation filed an action seeking a declaratory judgment that the new amendment erred by providing for a geographic limit on the original law.
Why is the case important?
Plaintiffs brought suit requesting an injunction requiring the Secretary of the Interior (Secretary) to reinstate an initial interpretation of the Endangered Species Act of 1973 (ESA). The initial interpretation applied the Act to actions taken in foreign nations. The Secretary claimed that the Plaintiffs lacked standing.
Plaintiffs have standing to challenge the Secretary’s interpretation of the ESA under either traditional rules of standing or the individual cause of action created within the ESA?
No. Judgment reversed.
The case and controversy requirement of Article III creates three minimal elements in order to have standing. The plaintiff must have suffered (i) an “injury in fact” (ii) there must be a causal connection between the injury and the conduct complained of and (iii) it must be likely that this injury will be redressed by a favorable decision.
In this case, the Plaintiffs failed to establish injury in fact or redressability. Because of the limited effect of the ESA, it is too speculative to claim that not enforcing an injunction on the Secretary would result in an injury in fact to any of the Plaintiffs. Likewise, it is too speculative to assume that any redress by the courts would have substantial impact on threatened species outside of the United States.
The Plaintiff’s claim that they suffered a “procedural injury” established by a citizen-suit provision within the ESA is also without merit. To permit standing based on this Congressional Act would usurp the power of the Executive to “take Care that the Laws be faithfully executed.”
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.
- Advocates: Edwin S. Kneedler on behalf of the Petitioner Brian B. O’Neill on behalf of the Respondents
- Petitioner: Lujan
- Respondent: Defenders of Wildlife
- DECIDED BY:Rehnquist Court
- Location: Defenders of Wildlife
|Citation:||504 US 555 (1992)|
|Argued:||Dec 3, 1991|
|Decided:||Jun 12, 1992|