Facts of the Case
Petitioner Sierra Club, a membership corporation with a special interest in the conservation and sound maintenance of the national parks, game refuges, and forests of the country, brought this suit for a declaratory judgment and an injunction to restrain federal officials from approving an extensive skiing development in the Mineral King Valley in the Sequoia National Forest. Sierra Club relies on § 10 of the Administrative Procedure Act, which accords judicial review to a person suffering legal wrong because of agency action, or who is adversely affected or aggrieved by agency action within the meaning of a relevant statute. On the theory that this was a public action involving questions as to the use of natural resources, Sierra Club did not allege that the challenged development would affect the club or its members in their activities or that they used Mineral King, but maintained that the project would adversely change the area’s aesthetics and ecology. The District Court granted a preliminary injunction. The Court of Appeals reversed, holding that the club lacked standing, and had not shown irreparable injury.
Did the Sierra Club adequately establish that it had a sufficient stake in the development of the Mineral King Valley to establish standing for a suit under the Administrative Procedure Act?
The Sierra Club did not have standing to sue under the Administrative Procedure Act (APA) because it failed to show that any of its members had suffered or would suffer injury as a result of the defendants’ actions. Justice Potter Stewart wrote the opinion for the 4-3 majority, in which the Court held that, in order to have standing to sue under the APA, the plaintiffs must demonstrate they had directly suffered an injury as a result of the actions that led to the suit. Although building roads and high voltage power lines through the wilderness upsets the beauty of the area and the enjoyment of some, such “general interest” in a potential problem is not sufficient to establish that a plaintiff has been injured in the manner that standing doctrine requires.Justice William O. Douglas wrote a dissenting opinion in which he argued that the standing doctrine should allow environmental organizations such as the Sierra Club to sue on behalf of inanimate objects such as land. There is precedent for inanimate objects to have legal personality for the purpose of lawsuits, and “[t]hose who have that intimate relation with the inanimate object about to be injured, polluted, or otherwise despoiled are its legitimate spokesmen.” In his separate dissenting opinion, Justice Harry A. Blackmun argued that, when faced with new issues of potentially enormous and permanent consequences, such as environmental issues, the Court should not be quite so rigid about its legal requirements. Justice Blackmun proposed two alternatives for how to proceed in this case: either the Sierra Club’s request for preliminary injunction should be granted while it is given time to amend its complaint to comport with the requirements of the standing doctrine, or the Court should expand the traditional standing doctrine to allow this type of litigation. Justice William J. Brennan, Jr. also wrote a separate dissent in which he agreed with Justice Blackmun regarding the Sierra Club’s standing and argued that the Court should have considered the case on its merits.Justice Lewis F. Powell, Jr. and Justice William H. Rehnquist took no part in the consideration or decision of this case.
- Citation: 405 US 727 (1972)
- Argued: Nov 17, 1971
- Decided Apr 19, 1972Granted: Feb 21, 1971