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Lujan v. Defenders of Wildlife

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Administrative Law Keyed to Strauss

Citation. Lujan v. Defenders of Wildlife, 504 U.S. 555, 112 S. Ct. 2130, 119 L. Ed. 2d 351, 1992 U.S. LEXIS 3543, 60 U.S.L.W. 4495, 92 Cal. Daily Op. Service 4985, 92 Daily Journal DAR 7876, 92 Daily Journal DAR 8967, 22 ELR 20913, 34 ERC (BNA) 1785, 6 Fla. L. Weekly Fed. S 374 (U.S. June 12, 1992)

Brief Fact Summary. The Secretary of Interior (Secretary) promulgated a rule interpreting Section:7 of the Endangered Species Act (Act) as applicable only to actions within the United States or on the high seas. The Defenders of Wildlife (Respondents) brought a challenge to the rule, and the District Court granted summary judgment against them for lack of standing.

Synopsis of Rule of Law. Article III, Section:1 of the United States Constitution limits the jurisdiction of federal courts to “cases” and “controversies,” known as the doctrine of standing. To have standing, a plaintiff must have an injury-in-fact; 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.

Facts. Respondents filed this action against the Secretary seeking a declaratory judgment that the new regulation was in error as to the scope of Section:7(a)(2) of the Act, and an injunction requiring 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, and the Court of Appeals reversed 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.

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

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