Editing Standing (law) (section)

===Recent development of the doctrine===
In 1984, the Supreme Court reviewed and further outlined the standing requirements in a major ruling concerning the meaning of the three standing requirements of injury, causation, and redressability.<ref>''Allen v. Wright'', 468 U.S. at 752 (1984).</ref> In the suit, parents of black public school children alleged that the Internal Revenue Service was not enforcing standards and procedures that would deny tax-exempt status to racially discriminatory private schools. The Court found that the plaintiffs did not have the standing necessary to bring suit.<ref name="avw755">''Allen v. Wright'', 468 U.S. at 755 (1984).</ref> Although the Court established a significant injury for one of the claims, it found the causation of the injury (the nexus between the defendant's actions and the plaintiff's injuries) to be too attenuated.<ref name="avw755" /> "The injury alleged was not fairly traceable to the Government conduct respondents challenge as unlawful".<ref>''Allen v. Wright'', 468 U.S. at 757 (1984).</ref>

In another major standing case, ''[[Lujan v. Defenders of Wildlife]]'', 504 U.S. 555 (1992), the Supreme Court elaborated on the redressability requirement for standing.<ref name="Lujan v 1992"/> The case involved a challenge to a rule promulgated by the [[United States Secretary of the Interior|Secretary of the Interior]] interpreting §7 of the [[Endangered Species Act of 1973]] (ESA). The rule rendered §7 of the ESA applicable only to actions within the United States or on the high seas. The Court found that the plaintiffs did not have the standing necessary to bring suit, because no injury had been established.<ref>''Lujan v. Defenders of Wildlife'', 504 U.S. at 562.</ref> The injury claimed by the plaintiffs was that damage would be caused to certain species of animals and that this in turn injures the plaintiffs by the reduced likelihood that the plaintiffs would see the species in the future. The court insisted though that the plaintiffs had to show how damage to the species would produce imminent injury to the plaintiffs.<ref>''Lujan v. Defenders of Wildlife'', 504 U.S. at 564.</ref> The Court found that the plaintiffs did not sustain this burden of proof. "The 'injury in fact' test requires more than an injury to a cognizable interest. It requires that the party seeking review be himself among the injured".<ref>''Lujan v. Defenders of Wildlife'', 504 U.S. at 563.</ref> The injury must be imminent and not hypothetical.

Beyond failing to show injury, the Court found that the plaintiffs failed to demonstrate the standing requirement of redressability.<ref>''Lujan v. Defenders of Wildlife'', 504 U.S. at 568.</ref> The Court pointed out that the respondents chose to challenge a more generalized level of government action, "the invalidation of which would affect all overseas projects". This programmatic approach has "obvious difficulties insofar as proof of causation or redressability is concerned".

In a 2000 case, ''[[Vermont Agency of Natural Resources v. United States ex rel. Stevens]]'', 529 U.S. 765 (2000),<ref name=VermontANR/> the [[Supreme Court of the United States|United States Supreme Court]] endorsed the "partial assignment" approach to ''[[qui tam]]'' relator standing to sue under the [[False Claims Act]] — allowing private individuals to sue on behalf of the U.S. government for injuries suffered solely by the government.<ref>Nathan D. Sturycz, ''The King and I?: An Examination of the Interest Qui Tam Relators Represent and the Implications for Future False Claims Act Litigation'', 28 St. Louis Pub. L. Rev. 459 (2009), available at https://ssrn.com/abstract=1537749. For the general standing rule, see {{ussc|name=Lujan v. Defenders of Wildlife|504|555|1992}}.</ref>

In a 2009 case, ''[[Summers v. Earth Island Institute]],'' 555 U.S. 488 (2009),<ref name="ReferenceA">{{ussc|name=Summers v. Earth Island Institute|555|488|2009}}</ref> the Supreme Court held the petitioner environmental organizations' claim that it was "statistically likely" that some of their members would visit the affected lands was insufficient to support Article III standing. The majority opinion stated the "deprivation of a procedural right without some concrete interest that is affected by the deprivation . . . is insufficient to create Article III standing."<ref name="ReferenceA"/>