In the 1980 case California et al. v. Sierra Club et al., the U.S Supreme Court ruled that private citizens or organizations do not have standing to challenge federal land-use decisions unless they can demonstrate a specific, tangible injury resulting from those decisions. The Sierra Club had sued to prevent development in the Mineral King Valley of Sequoia National Forest, arguing that it would cause environmental harm and interfere with their members' recreational use of the area. However, because they could not show any particularized harm distinct from that suffered by other members of public, they were found to lack legal standing under Article III of Constitution which requires an "injury in fact". This decision clarified and narrowed who has standing to sue over government actions affecting public lands.

In the dissenting opinion for California et al. v. Sierra Club et al., Justice William Brennan disagreed with the majority's interpretation of Section 10(a) of the Rivers and Harbors Appropriation Act of 1899, which he believed was intended to protect public rights in navigable waters from any encroachment without congressional approval. He argued that this section should be read as a broad prohibition against unauthorized obstructions, not limited only to those obstructing navigation but also including those causing environmental harm or altering natural conditions. The majority's narrow reading, according to him, undermined Congress' intent and left significant harms unaddressed by federal law. Furthermore, he contended that even if there were ambiguity in interpreting Section 10(a), it should be resolved in favor of protecting public interests rather than private ones.