Lujan v. National Wildlife Federation, 497 U.S. 871 (1990)
Lujan v. National Wildlife Federation is a cornerstone administrative law and federal courts case that crystallizes two enduring constraints on public law litigation: the need for plaintiffs to prove standing with specific, admissible facts at the summary judgment stage, and the Administrative Procedure Act's insistence that judicial review target discrete, final agency actions rather than amorphous agency "programs." Writing for the Court, Justice Scalia set boundaries on both who can sue and what can be sued under the APA, thereby shaping environmental and regulatory litigation strategy for decades.
Whether plaintiffs may maintain a broad, programmatic challenge to an agency's alleged "land withdrawal review program" under the APA without identifying a discrete, final agency action, and whether generalized affidavits sufficed to establish Article III standing at the summary judgment stage.
Under the APA, judicial review is available only for "final agency action" for which there is no other adequate remedy in court. 5 U.S.C. §§ 702, 704. "Agency action" is defined to encompass discrete actions such as a rule, order, license, sanction, relief, or the failure to act. 5 U.S.C. § 551(13). Plaintiffs must challenge an identifiable, discrete, and final action rather than an abstract "program" or general course of conduct. Additionally, Article III standing requires injury in fact, causation, and redressability; at the summary judgment stage, a plaintiff must set forth specific facts by affidavit or other evidence showing standing, not merely rely on allegations. Fed. R. Civ. P. 56(e).
The Supreme Court reversed the court of appeals, holding that NWF's broad challenge to the DOI/BLM "land withdrawal review program" did not identify a reviewable, final agency action under the APA and that NWF's affidavits failed to establish standing with the requisite specificity at the summary judgment stage. The district court's summary judgment for the government was reinstated.
Lujan v. National Wildlife Federation is a foundational case on two fronts. First, it limits APA litigation to discrete, final agency actions, precluding sweeping, across-the-board "program" challenges. This principle later anchors cases like Norton v. SUWA, which require a specifically identifiable agency duty or action. Second, it elevates the evidentiary rigor for Article III standing at summary judgment: plaintiffs must submit competent, specific evidence tying an injury to the particular agency action challenged. For environmental and administrative litigants, Lujan instructs that suits must be structured around concrete, reviewable decisions, with member declarations that establish a direct, site-specific nexus to those decisions. For civil procedure, it underscores Rule 56's demand for specific facts and the inadmissibility of vague or conclusory affidavits.