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Administrative Law Keyed to Funk
Lujan v. National Wildlife Federation
Citation:
497 U.S. 871 (1990)Facts
The Bureau of Land Management (BLM) administered a “land withdrawal review program” that involved reviewing and reclassifying public lands, including terminating withdrawals that had protected certain lands from mining and other development. The National Wildlife Federation (NWF) filed suit alleging that the program violated the Federal Land Policy and Management Act, the National Environmental Policy Act, and the Administrative Procedure Act. NWF claimed these violations would harm the environment and diminish their members’ recreational use and aesthetic enjoyment of the affected lands. To establish standing, NWF submitted affidavits from members who claimed to use lands “in the vicinity” of areas affected by specific BLM decisions. After the District Court granted a preliminary injunction, the case proceeded to summary judgment. The District Court found NWF’s affidavits insufficient to establish standing because they failed to show that members used the specific lands affected by the challenged actions. The Court of Appeals reversed, finding the affidavits adequate and also holding that the District Court abused its discretion in refusing to consider supplemental affidavits submitted after the summary judgment hearing.
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