Lujan v

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St. Mary's University *

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Law

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Apr 3, 2024

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docx

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Lujan v. Defenders of Wildlife Citation Lujan v. Defenders of Wildlife , 504 U.S. 555 (1992). Parties Petitioner/Appellant/Defendant Manuel Archibald Lujan Jr., Secretary of the Interior. Respondent/Appellees/Plaintiffs Defenders of Wildlife, wildlife conservation and other environmental organizations who joined to sue. History of the litigation/Procedural posture The petitioner amended § 7 of the Endangered Species Act of 1974 (ESA) limiting the extent of suits that could be brought against government entities for violations to the United States or high seas only. Previously, the ESA permitted plaintiffs to bring suits for violations in foreign countries. The respondents filed suit seeking declaratory judgement and injunctive relief for the restoration of the original scope of the ESA’s § 7. The district court ruled agreed with the petitioner’s interpretation and dismissed the suit for lack of standing. Respondent appealed to the circuit court which then reversed. Case was sent to the Supreme Court under a writ of certiorari. Key facts  Section 7(a)(2) of the Endangered Species Act of 1973 (ESA) states that the protection of endangered species should be undertaken by the Secretary of the Interior and the Secretary of Commerce. Both of these agencies should consult and collaborate with each other in order to best protect endangered and threatened species.  Both agencies consulted and then enacted a change to § 7 of the ESA limiting suits to the governmental actions taken only in the United States or high seas. The previous regulation allowed for suits to be brought for actions taken in foreign nations.  Defenders of Wildlife then filed suit seeking declaratory judgement on the scope of the new regulation and an injunction requiring for the original scope and interpretation of § 7 to be reinstated. Issue(s) Whether Defenders of Wildlife has standing to sue and should be granted declaratory judgement and injunctive relief for the restoration of the original wording and scope of the Endangered Species Act of 1974 § 7. Rule  The respondents bear the burden of proving that they have sufficient standing by providing proof that they have suffered injury in fact (concrete, particularized, actual or imminent action of a legally protected interest). Specific facts must be given to support the claim of injury.  Article III - the plaintiff must have suffered an "injury in fact." Reasoning/Rationale/Analysis/Application The Court determined that the respondents failed to prove any injury in fact suffered. None of the members of Defenders of Wildlife would be directly affected by the new § 7 other than their special interest. The Court referred to Sierra Club v.

Morton , where it was established that respondents must sustain or provide proof of an injury beyond a special interest. In this case, the respondents expressed an interest in returning to view endangered species some indefinite time in the future which is does not demonstrate an “imminent” injury. The respondents speculated that the harming of an ecosystem would harm anyone who was part of it. This theory was first proposed by the respondents in Lujan v. National Wildlife Federation . The Court held that the theory did not support a specialized interest in this suit. The Court held that precedent has established that a general grievance against the government, without a specific, legally protected injury does not fulfill Article III’s definition of case or controversy. Fairchild v. Hughes. Holding(s) The Court reversed and remanded the judgement of the circuit court because the respondents, Defenders of Wildlife, lacked standing to be able to bring forth the action.

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