Sierra Club v. Morton
405 U.S. 727 (1972)
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Rule of Law:
To have standing to sue under the Administrative Procedure Act, an organization must allege that its members are suffering a concrete and particularized injury in fact, which can include aesthetic and recreational harm. A mere organizational interest in a problem, no matter how specialized or long-standing, is insufficient to establish standing.
Facts:
- The Mineral King Valley is a quasi-wilderness area within California's Sequoia National Forest.
- In the late 1940s, the U.S. Forest Service began considering the valley for recreational development.
- In 1965, the Forest Service invited bids from private developers to build a large-scale ski resort in Mineral King.
- The Forest Service selected a proposal from Walt Disney Enterprises, Inc. for a $35 million complex designed to accommodate 14,000 daily visitors.
- The approved plan included motels, restaurants, ski lifts, and other structures on 80 acres of the valley floor.
- The project also required the construction of a new 20-mile highway and a high-voltage power line, parts of which would traverse the adjacent Sequoia National Park.
- The Sierra Club, a conservation organization, had a long-standing interest in the preservation of the Sierra Nevada mountains and opposed the development plan.
Procedural Posture:
- The Sierra Club sued federal officials in the U.S. District Court for the Northern District of California seeking to enjoin the Mineral King development project.
- The District Court, a court of first instance, found the Sierra Club had standing and granted a preliminary injunction.
- The federal officials (respondents) appealed the injunction to the U.S. Court of Appeals for the Ninth Circuit, an intermediate appellate court.
- The Court of Appeals reversed the District Court's order, holding that the Sierra Club lacked standing because it had not alleged individualized injury to itself or its members.
- The Sierra Club (petitioner) sought and was granted a writ of certiorari by the U.S. Supreme Court, the highest federal court.
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Issue:
Does a membership organization have standing to challenge a federal agency action under the Administrative Procedure Act by asserting a special interest in the subject matter, without alleging that its members are individually harmed by the action?
Opinions:
Majority - Mr. Justice Stewart
No. To have standing under the Administrative Procedure Act (APA), a plaintiff must allege that they have suffered an "injury in fact." While harm to aesthetic, conservational, and recreational interests is a cognizable injury, the party seeking review must itself be among the injured. The Sierra Club's complaint failed to allege that its members actually use the Mineral King valley for any purpose, and therefore did not show how they would be individually harmed by the proposed development. An organization's mere 'interest in a problem' is not sufficient to render it 'adversely affected or aggrieved' under the APA; it cannot establish standing simply by asserting its expertise and commitment to a cause as a representative of the public.
Dissenting - Mr. Justice Douglas
Yes. The Court should fashion a new federal rule allowing environmental issues to be litigated in the name of the inanimate object being threatened. Natural objects like valleys, rivers, and forests should be granted standing to sue for their own preservation, with conservation groups and individuals who have a meaningful relationship to the object serving as their legal spokespersons. This approach would ensure that the ecological values of these natural wonders are represented in court before they are destroyed by development, moving beyond a purely anthropocentric view of legal injury.
Dissenting - Mr. Justice Blackmun
Yes. The traditional notions of standing are too inflexible for critical environmental litigation. The Court should have either (1) reversed the appellate court on the condition that the Sierra Club amend its complaint to allege individualized injury to its members, as the underlying legal issues were substantial, or (2) expanded the concept of standing to permit a bona fide and dedicated organization like the Sierra Club to litigate on behalf of the environment. The Court's rigid procedural ruling will likely lead to the irreversible destruction of Mineral King before the serious merits of the case can be considered.
Dissenting - Mr. Justice Brennan
Yes. Justice Brennan agreed with the reasoning set forth by Justice Blackmun and would have found that the Sierra Club had standing to bring the suit.
Analysis:
This decision solidified the 'injury in fact' requirement for standing in environmental law, clarifying that an abstract interest in a subject is insufficient. While appearing as a procedural loss for environmentalists, the opinion provided a clear roadmap for future litigation: organizations could easily establish standing by simply identifying one or more members who used the affected area and would suffer personal aesthetic or recreational harm. This transformed the ruling from a barrier into a simple pleading requirement, ultimately making it easier for environmental groups to get into court by slightly modifying their complaints to name affected members.
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