Does an environmental organization have legal standing to challenge federal government actions regarding public lands under the Administrative Procedure Act?

The National Wildlife Federation (NWF) initiated legal action against the U.S. Department of the Interior, its Secretary, and the Director of the Bureau of Land Management (BLM) in 1985. NWF alleged that the BLM's administration of the 'land withdrawal review program' violated the Federal Land Policy and Management Act, the National Environmental Policy Act, and the Administrative Procedure Act. The program involved BLM's review of withdrawal revocation applications, public land classifications, and land use plan development. NWF contended these actions would increase mining on public lands, resulting in environmental damage and reduced recreational opportunities for its members.

To establish standing, NWF initially provided affidavits from two members, Peggy Kay Peterson and Richard Erman, who claimed use of lands 'in the vicinity' of areas affected by BLM's actions. Following a hearing on summary judgment motions, NWF attempted to submit additional affidavits from other members to further support their case.

NWF initiated the lawsuit in 1985 in the U.S. District Court for the District of Columbia. The District Court initially granted NWF's motion for a preliminary injunction and denied the government's motion to dismiss. The Court of Appeals affirmed both of these orders.

Subsequently, in the District Court, the government moved for summary judgment, contending that NWF lacked standing. The District Court granted this motion and vacated the injunction. The court also rejected NWF's attempt to submit additional affidavits, deeming them untimely.

NWF appealed this decision. The Court of Appeals reversed the District Court's ruling, finding that the original affidavits were sufficient to establish standing. The appellate court also held that the District Court's refusal to consider the additional affidavits constituted an abuse of discretion.

Following this, the Supreme Court granted certiorari to review the case.

(Scalia, J.)

No. An environmental organization lacks standing to challenge federal government actions regarding public lands under the Administrative Procedure Act without demonstrating specific, concrete harm from identifiable agency actions. The affidavits submitted by the National Wildlife Federation failed to establish standing for summary judgment purposes by not identifying specific "agency action" that affected the affiants in a concrete way, as required by the APA. General averments in affidavits are insufficient to withstand a summary judgment motion; specific facts are required. The APA does not allow for broad programmatic attacks on agency policies or practices. Judicial review under the APA is limited to discrete agency actions that cause harm to the plaintiff. An organization cannot seek wholesale improvement of an agency's land management program through judicial decree, as this does not constitute a specific "agency action" reviewable under the APA. Standing requires a showing of injury-in-fact that is both concrete and particularized, as well as actual or imminent. The injury must be fairly traceable to the challenged action and likely to be redressed by a favorable decision. Generalized grievances shared by the public at large do not meet this standard. Environmental organizations must demonstrate that their members use the specific areas affected by the challenged agency action and are persons "for whom the aesthetic and recreational values of the area will be lessened" by that action. Affidavits that speak only of activities "in the vicinity" of vast tracts of public lands are insufficient to show the required level of localized harm. The stringent nature of the summary judgment standard in this context serves to prevent courts from becoming general overseers of agency action based on abstract concerns rather than concrete disputes.

Dissent (Blackmun, J.) The original affidavits were sufficient to create a genuine issue of fact regarding NWF's standing. The District Court abused its discretion by refusing to consider the supplemental affidavits, given the circumstances of the case and the principles of the Federal Rules of Civil Procedure. This overly strict interpretation of standing requirements and procedural rules unduly restricts public interest groups' ability to challenge broad agency actions, potentially limiting judicial oversight of administrative decisions. The majority's approach fails to recognize the practical realities of challenging large-scale government programs and sets an unreasonably high bar for environmental organizations seeking to protect public lands.