Warth, Lujan v. Defenders of Wildlife

In Warth, Lujan v. Defenders of Wildlife, 504 U.S. 555 (1992), organizations dedicated to wildlife conservation challenged the interpretation of the Endangered Species Act by the United States Department of the Interior. 504 U.S. at 557-58. The Supreme Court ruled that to adequately assert standing the complaint must reflect the "continuing, present adverse effects" of illegal conduct and a direct effect on one or more members of an organization apart from the organization's special interest in conservation. Id. at 563. Affidavits from organization members that alleged no continuing adverse effects were insufficient because they failed to show actual or imminent harm. Id. at 563-64. The Court also declined to find standing under a "'vocational nexus approach' under which anyone with a professional interest in the endangered animals could sue." Id. at 566. It characterized as "pure speculation and fantasy" the assertion that anyone who observed or worked with an endangered species was appreciably harmed by a project affecting some portion of that species with which the person had no particular connection. Id. at 567.