In the case of Aberdeen & Rockfish Railroad Co. et al. v. Students Challenging Regulatory Agency Procedures (SCRAP) et al., 1974, the U.S Supreme Court ruled on a dispute involving environmental law and standing to sue in federal court. The SCRAP group, composed of five law students from George Washington University, challenged an Interstate Commerce Commission decision that allowed railroads to increase freight rates by 2.5%. They argued this would lead to increased use of non-recyclable goods due to higher costs for transporting recyclables, thereby harming the environment and violating their rights as citizens under National Environmental Policy Act (NEPA). The railroad companies contested their standing but the Supreme Court held that SCRAP had established injury-in-fact sufficient for Article III standing because they used forests affected by pollution caused indirectly by rate changes; thus affirming broad interpretation of "injury" in environmental cases.

In the dissenting opinion for Aberdeen & Rockfish Railroad Co. v. SCRAP, Justice Rehnquist expressed concern over the broad interpretation of "injury in fact" used by the majority to establish standing for SCRAP members. He argued that this expansive definition could potentially allow any individual or group with a generalized grievance against government action to bring suit, thereby flooding courts with cases and undermining their ability to function effectively. Furthermore, he contended that such an approach blurred the separation of powers by allowing judicial intervention into matters more appropriately handled by legislative or executive branches. In his view, it was not enough for plaintiffs simply to allege injury; they needed concrete proof of harm directly linked to defendant's actions.