The Judicial Power: Case and Controversy Requirement: Standing Flashcards
Requirements for Standing
- The plaintiff has an injury that is concrete and exists or will exist imminently. Article III requires invasion of a legally-protected right to have standing
- The defendant caused the injury
- The court has the power to remedy the issue.
Singleton v. Wulff
Litigants have standing to represent third parties when they are an integral part of the case and the third party can’t or won’t represent herself.
Singleton v. Wulff
Issue
Whether the plaintiff-appellees, as physicians who perform nonmedically indicated abortions, have standing to maintain the suit
Singleton v. Wulff
Facts
Medicaid issued a rule that it would not pay for non-medically necessary abortions. Plaintiff was a doctor suing Medicaid on behalf of his poor patients.
Singleton v. Wulff
Reasoning
There is adversity between the parties. The patients’ dependance on the doctors created a relationship where the doctors’ advocacy would be as effective as the patients’. The patients’ ability to represent themselves is impaired by maintaining their privacy, and the limited amount of time before the case is moot makes it impossible for women to apply to Medicaid, be denied coverage and bring a suit challenging the denial.
Singleton v. Wulff
Holding
Plaintiff had standing.
Havens Realty Corp. v. Coleman
A statute creating actual or threatened harm can establish a legal right for standing.
Havens Realty Corp. v. Coleman
Issue
Whether the respondents have standing based on the FHA
Havens Realty Corp. v. Coleman
Facts
A blank person, Coles, tried to rent an apartment from defendant and was told there were no vacancies. Testers from Housing Opportunities Made Equal (HOME) went to the apartment manager and asked about vacancies. The white tester, Willis, was told there were and the black one, Coleman, was told they weren’t, so HOME found that defendant discriminated against blacks.
Havens Realty Corp. v. Coleman
Reasoning/Holding
The FHA created a right to the truth for “any individual.” The Coles and Coleman weren’t told the truth so they had standing. Willis did not have standing because he was told the truth.
Lujan v. Defenders of Wildlife
To have standing under Article III, plaintiffs must show concrete and personal injury that is actual or imminent. There must be a causal connection between the plaintiff’s injury and the defendant’s actions. And the injury must be one the court can redress. Plaintiffs can’t bring suits that claim to harm everyone’s interests.
Lujan v. Defenders of Wildlife
Issue
Whether the respondents had standing based on the Endangered Species Act.
Lujan v. Defenders of Wildlife
Facts
The Fish and Wildlife Service and the National Marine Fisheries Service issued regulations saying section 7 of the ESA applied to foreign nations but then reversed their regulations. The reversal would increase the extinction of endangered species. Respondents wanted the courts to reverse this. Their arguments were that 2 of their members suffered harm because they planned to visit places where endangered species lived someday, and section 7(a)(2) of the ESA established right for anyone to sue any person or entity that violated the act.
Lujan v. Defenders of Wildlife
Reasoning
That 2 of the Defender’s members visited places where endangered species are threatened by development, planned to return someday and were afraid that the development will threaten their opportunity to see the endangered species does not meet actual or imminent personal, concrete harm. Also, the respondents’ reading of the civil suit clause was too broad and would violate Article III’s requirement of personal injury. In addition, the only redress would be to terminate funding for the projects that were causing the species to die off more quickly and none of the funding agencies were not bound by the Court’s ruling, so there would be no relief.
Lujan v. Defenders of Wildlife
Holding
The respondents lacked standing.
Spokeo LLC v. Robins
To have Article III standing, a plaintiff must have a “concrete and particularized” injury
Spokeo LLC v. Robins
Issue
Whether a plaintiff must show a “concrete and particularized” injury to have standing.
Spokeo LLC v. Robins
Facts
Plaintiff found out that Spokeo gave a third party inaccurate information about him in violation of Fair Credit Reporting Act of 1970.
Spokeo LLC v. Robins
Reasoning
Concrete injuries don’t have to be tangible. To determine an injury is concrete, a court must look at history and Congress’ judgment. Look at whether the injury is similar to an injury in traditional American or English law. Congress is well positioned to identify intangible harms and create laws to protect against them. The risk of concrete harm might be enough for standing.
Spokeo LLC v. Robins
Holding
Remand to decide whether Robins’ injury was concrete.
TransUnion LLC v. Ramirez
To have Article III standing, plaintiffs must have concrete harm. A key way to assess this is to compare plaintiffs’ harm to a traditional basis for a lawsuit
TransUnion LLC v. Ramirez
Issue
Whether all the plaintiffs had a concrete harm.
TransUnion LLC v. Ramirez
Facts
Plaintiff alleged defendant did not ensure the accuracy of his credit files. Spokeo used a screening program that flagged names of drug trafficker, terrorists and other criminals but didn’t distinguish between people with the same name. Plaintiff could not buy a car because his credit report said he was a terrorist or drug trafficker. Sued individually and as a class of 8,185 plaintiffs.
TransUnion LLC v. Ramirez
Reasoning/Holding
Even if Congress creates a legal harm and the to sue for the injury, it does not mean that plaintiffs have an injury in fact, which is necessary for standing. The court must look at each case to decide whether there is an injury in fact. Only plaintiffs who had incorrect information disseminated about them had standing because that harm was closely related to defamation
Federal Election Commission v. Akins
Injury that is widely shared and abstract and indefinite but concrete can justify standing. Here, the Federal Election Commission decided that a lobbying group didn’t have to disclose information about its members. Voters sued and SCOTUS said there was concrete harm because the FEC deprived them of information that would inform their vote.
Friends of the Earth
Penalties paid to the government can redress plaintiffs’ injury because they discourage defendants from ignoring the law. Therefore, defendants no longer harm plaintiffs
Massachusetts v. Environmental Protection Agency
States have standing as quasi-sovereigns. Massachusetts sued the EPA to compel it to regulate gas emissions that contributed to global warming. The global warming already caused the state to lose land due to flooding. This was redressable because regulating gas emissions would slow future damage.
