Friends of the Earth v. laidlaw and the Increasingly Broad Standard for Citizen Standing to Sue in Environmental litigation

摘要

In Friends of the Earth v. Laidlaw Environmental Services, Inc., the united States Supreme Court created a framework through Which citizen groups may sue those who violate environmental Protection statutes such as the Clean Water Act. The Court held That citizens may obtain "standing" to bring an enforcement action If (1) they are "injured in fact", even if that injury amounts to no more than "concerns" about the polluter's activities; (2) the polluter "causes" that concern; and (3) the harm can be "redressed" by forcing the polluter to pay a fine, even if the proceeds are not paid to the plaintiffs themselves.