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Sierra Club v. Morton, 405 U.S. 727, 92 S.Ct. 1361, 31 L.Ed.2d 636, 3 ERC 2039, 1 Envtl. L. Rep. 29,001, 2 Envtl. L. Rep. 20,192

Facts

The Sierra Club filed suit against federal officials to block the development of a ski resort in the Mineral King Valley, which is part of the Sequoia National Forest and designated as a national game refuge. The Forest Service had approved a plan by Walt Disney Enterprises for a $35 million resort, which included extensive construction and infrastructure. The Sierra Club argued that the project would harm the area's aesthetics and ecology but did not allege that its members used the area or would be directly affected by the development.

Representatives of the Sierra Club, who favor maintaining Mineral King largely in its present state, followed the progress of recreational planning for the valley with close attention and increasing dismay.

Issue

Did the Sierra Club have standing to sue under the Administrative Procedure Act to challenge the federal approval of the ski resort project?

The first question presented is whether the Sierra Club has alleged facts that entitle it to obtain judicial review of the challenged action.

Rule

A party has standing to seek judicial review under the Administrative Procedure Act only if they can show that they themselves have suffered or will suffer injury, whether economic or otherwise.

A person suffering legal wrong because of agency action, or adversely affected or aggrieved by agency action within the meaning of a relevant statute, is entitled to judicial review thereof.

Analysis

The Supreme Court applied the standing requirement by emphasizing that the Sierra Club failed to allege any specific, individualized harm to itself or its members resulting from the proposed ski resort. The Court noted that while aesthetic and environmental interests are important, the Sierra Club needed to demonstrate a direct stake in the outcome of the controversy, which it did not do.

The impact of the proposed changes in the environment of Mineral King will not fall indiscriminately upon every citizen. The alleged injury will be felt directly only by those who use Mineral King and Sequoia National Park, and for whom the aesthetic and recreational values of the area will be lessened by the highway and ski resort.

Conclusion

The Supreme Court affirmed the Ninth Circuit's ruling that the Sierra Club lacked standing to maintain the action, thereby allowing the ski resort project to proceed.

As we conclude that the Court of Appeals was correct in its holding that the Sierra Club lacked standing to maintain this action, we do not reach any other questions presented in the petition, and we intimate no view on the merits of the complaint.

Who won?

The federal officials prevailed in the case because the Supreme Court found that the Sierra Club did not have standing to challenge the project, as it failed to show any direct injury.

The Court of Appeals held that the Sierra Club had no made an adequate showing of irreparable injury and likelihood of success on the merits to justify issuance of a preliminary injunction.

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