In Warth v. Seldin, 422 U.S. 490 (1975), various organizations and individuals sued a town and town officials, asserting that a zoning ordinance effectively excluded persons of low and moderate income. 422 U.S. at 493. A local home builders association, which included a number of area residential construction firms, sought to intervene, id. at 497, but the district court dismissed its complaint for lack of standing. Id. at 498. Four of the individual plaintiffs were low or moderate income residents of Rochester, New York. They alleged that a zoning ordinance in the nearby town of Penfield purposely excluded low and moderate income persons from living in the town. (422 U.S. at p. 495 45 L.Ed.2d at pp. 352-353.) The alleged harm was that "Penfield's zoning practices had prevented them from acquiring, by lease or purchase, residential property in the town, and thus had forced them and their families to reside in less attractive environments." (422 U.S. at p. 496 .) Among other remedies, these plaintiffs sought declaratory and injunctive relief. The United States Supreme Court affirmed. It explained that an organization like the association there might seek relief on its own behalf and assert the rights of its members, provided that such association alleged that "its members, or any one of them, are suffering immediate or threatened injury as a result of the challenged action of the sort that would make out a justiciable case had the members themselves brought suit." Id. at 511. In addition, the Court observed that whether an association had standing "depended in substantial measure on the nature of the relief sought" and that in most cases in which the Court had found standing, the subject association had sought declarative or injunctive relief. Id. at 515. It also emphasized that the nature of the claim could not make participation of each injured party indispensable to the proper resolution of the suit. Id. In Warth, the association had alleged that the zoning ordinance and the denials of variances "deprived some of its members of 'substantial business opportunities and profits.'" Id. at 514-15. The injury from lost profits, however, was "peculiar to each individual member," id. at 515, and thus the alleged damage was neither "common to the entire membership nor shared by all in equal degree but . . . the fact and extent of injury would require individualized proof." Id. at 515-16. The Court therefore held that the association lacked standing to claim damages on behalf of its members. Id. at 516. In Warth v. Seldin, the United States Supreme Court addressed the Article III standing requirements for associations. The Court held that an association must allege that its members, or any one of them, are suffering immediate or threatened injury as a result of the challenged action of the sort that would make out a justiciable case had the members themselves brought suit. So long as this can be established, and so long as the nature of the claim and the relief sought does not make the individual participation of each injured party indispensable to proper resolution of the cause, the association may be an appropriate representative of its members, entitled to invoke the court's jurisdiction. Warth, 422 U.S. at 511. The court in Warth detailed a two-prong test for standing in exclusionary zoning cases and held that the four low and moderate income plaintiffs had failed that test. The Warth standard is that plaintiffs "must allege facts from which it reasonably could be inferred that, absent the respondents' restrictive zoning practices, there is a substantial probability that they would have been able to purchase or lease in Penfield and that, if the court affords the relief requested, the asserted inability of plaintiffs will be removed." (422 U.S. at p. 504.) The Warth plaintiffs lacked standing, the court said, because "the facts alleged fail to support an actionable causal relationship between Penfield's zoning practices and plaintiffs' asserted injury." (422 U.S. at p. 507.) The court stated that the plaintiffs' "desire to live in Penfield always has depended on the efforts and willingness of third parties to build low- and moderate-cost housing." (422 U.S. at p. 505.) Since the plaintiffs did not claim that a particular housing project which would have satisfied their needs would have been built in Penfield but for Penfield's zoning practices, they demonstrated to the court neither the "substantial probability" of a "causal relationship" between Penfield's actions and plaintiffs' injuries, nor that the requested relief would probably remove the harm. The court held that a plaintiff challenging zoning practices need not necessarily "have a present contractual interest in a particular project," but that "usually the initial focus should be on a particular project." (422 U.S. at p. 508, fn. 18.) Under the Warth standard, a "causal relationship" between the acts of the city and the injuries asserted would be required to be demonstrated by alleging a specific housing project that would have been built but for the zoning practices. The "causal relationship" and "substantial probability" requirements show the concern that the practices being attacked may be irrelevant to the injuries; that even if the city had the least restrictive zoning ordinances imaginable, the plaintiffs would be in no better position until third parties, the builders, voluntarily made the commitment to construct housing for low and moderate income persons.