The U.S. Supreme Court case Friends of the Earth, Inc., et al. v. Laidlaw Environmental Services (TOC), Inc., 1999 revolved around a dispute over environmental pollution and citizen standing to sue for potential violations of the Clean Water Act by Laidlaw Environmental Services. The company had been discharging pollutants into a South Carolina river beyond permitted levels, leading non-profit environmental organizations to file suit on behalf of their members who lived nearby and used the affected waterways for recreational purposes like fishing or bird-watching. The lower courts were divided on whether these groups had legal standing - that is, whether they could demonstrate sufficient harm from Laidlaw's actions to justify their lawsuit in court. In its decision, the Supreme Court ruled in favor of Friends of the Earth and other plaintiffs, affirming that they did have standing due to "reasonable concern" about harmful effects from pollution which directly impacted their use and enjoyment of natural resources in question even if no physical injuries occurred as result thereof; this was enough under law according statutory rights citizens enforce provisions Clean Water Act through civil litigation against alleged violators such as companies like Laidlaw.

In the dissenting opinion for Friends of the Earth, Inc. v. Laidlaw Environmental Services (TOC), Inc., Justice Scalia argued that plaintiffs lacked standing to sue because they failed to demonstrate a concrete and particularized injury resulting from Laidlaw's alleged violations of its permit under the Clean Water Act. He contended that mere allegations of subjective "reasonable concern" and "economic effect" were insufficient without proof of actual or imminent harm to their recreational, aesthetic, or economic interests caused by specific discharges exceeding permit limits. Furthermore, he disagreed with the majority's view on mootness; he believed that once Laidlaw achieved compliance before trial commenced, there was no ongoing case or controversy requiring judicial resolution since civil penalties could not redress past injuries nor deter future ones due to plant closure.