In the 1985 case International Union, United Automobile, Aerospace, and Agricultural Implement Workers of America v. Brock, Secretary of Labor, the Supreme Court ruled on whether unions could sue on behalf of their members to enforce provisions under Title I of the Comprehensive Employment and Training Act (CETA). The CETA was a federal law that provided funds for job training programs with certain protections for employees in those programs. Several local labor unions sued William E. Brock III as Secretary of Labor alleging violations by state officials administering these federally funded employment programs under CETA. The court held that labor organizations have standing to sue in federal court on behalf of their members when: (1) its members would otherwise have standing to sue in their own right; (2) the interests it seeks to protect are germane to its purpose; and (3) neither claim nor relief requires participation from individual union members. This decision affirmed that associations like trade unions can bring lawsuits forward not only for themselves but also representatively for any member who has suffered an injury-in-fact where legal rights are at stake.

In the dissenting opinion for International Union, United Automobile, Aerospace, and Agricultural Implement Workers of America v. Brock (1985), Justice White argued that the majority's decision to allow unions to sue on behalf of their members was a departure from traditional standing rules. He contended that allowing an organization to represent its members in court without showing direct injury or threat thereof undermines the requirement for concrete adverseness between parties. Furthermore, he expressed concern about potential conflicts of interest when organizations represent individuals who may not share identical interests or views with those pursued by the organization in litigation. In his view, this could lead to inadequate representation and potentially harm individual rights if they are not adequately protected during proceedings.