Sierra Club v. Morton (1972)
Sierra Club v. Morton (405 U.S. 727, 1972) was a landmark Supreme Court case on standing under the Administrative Procedure Act. The Court held that the Sierra Club lacked standing to challenge federal approval of a ski resort in Mineral King Valley because it failed to allege specific injury to itself or its members. This set the modern standard for standing in environmental litigation and inspired debates about legal rights for nature[1][2][3][4][5][6][7].
Key Events Timeline
- 1965-1969: U.S. Forest Service seeks proposals to develop Mineral King Valley, a pristine area in California’s Sierra Nevada[4][5][6].
- 1969: Walt Disney Enterprises wins bid for a $35 million ski resort, including hotels, restaurants, and a 20-mile access highway[5][6].
- 1969-1970: Sierra Club sues to block the project, arguing it would irreparably harm the valley’s ecology and aesthetics[1][5][6].
- 1970: District court grants preliminary injunction; Ninth Circuit reverses, holding Sierra Club lacked standing[1][3][4][5][6].
- Nov 17, 1971: Supreme Court hears arguments on standing[1][2][3].
- April 19, 1972: Supreme Court (4-3) rules Sierra Club lacked standing, as it did not allege injury to itself or its members[1][2][3][4][5][6][7].
- 1972-present: Case inspires new legal strategies for environmental standing and Justice Douglas’s famous dissent on rights of nature[4][6][7].
Supreme Court Vote
Mineral King Project and Environmental Standing: Quantitative Context
| Year | Project Status | Estimated Resort Cost ($M) | Expected Visitors/Day | Standing Requirement |
|---|---|---|---|---|
| 1969 | Proposal approved | 35 | 14,000 | Not defined |
| 1972 | Blocked by litigation | 35+ | 0 | Direct injury required |
| 1978 | Project abandoned | n/a | 0 | Direct injury; use/enjoyment |
| 2024 | Protected as wilderness | n/a | ~200 (hikers) | Modern standing doctrine |
Result: The Supreme Court’s decision set a strict standard for standing in environmental cases, requiring plaintiffs to show concrete, particularized injury, not just a general interest in environmental protection[1][2][3][4][5][6][7].
Legal Logic and Precedent
Key Holdings
- Standing Doctrine: Only a party who has suffered or will suffer a direct injury (economic, aesthetic, or otherwise) has standing to sue under the Administrative Procedure Act[1][2][3][5][6][7].
- Organizational Standing: Organizations must allege injury to themselves or their members, not just a special interest in an issue[1][2][3][5][6][7].
- Douglas Dissent: Justice Douglas argued for legal personhood for nature, inspiring later debates on rights of nature and natural asset companies[4][9].
Implications for Environmental and Administrative Law
| Area | Before Sierra Club v. Morton | After Sierra Club v. Morton |
|---|---|---|
| Standing in Court | Unclear; broad claims sometimes allowed | Direct, particularized injury required |
| Environmental Litigation | Organizations could sue on public interest grounds | Plaintiffs must show use/enjoyment or harm to members |
| Rights of Nature | No legal personhood for nature | Inspired debate and some later legal reforms[4][9] |
| Administrative Law | APA review available on broad “zone of interests” | APA review limited by constitutional standing requirements |
Why Sierra Club v. Morton Matters
Sierra Club v. Morton established the modern doctrine of standing in U.S. environmental law, requiring plaintiffs to show concrete, particularized injury. The decision limited “public interest” lawsuits but inspired new legal strategies and debates about the rights of nature, influencing both U.S. and global environmental law[1][2][3][4][5][6][7][9].
Key citation: Sierra Club v. Morton, 405 U.S. 727 (1972); Administrative Procedure Act §10.