In the 1991 case Manuel Lujan, Jr., Secretary of the Interior v. Defenders of Wildlife, et al., the U.S. Supreme Court ruled that a group of environmental organizations did not have standing to challenge regulations issued by the Secretary of Interior which interpreted Section 7(a)(2) of Endangered Species Act (ESA). The ESA required federal agencies to consult with other relevant departments before taking actions that could jeopardize endangered species in foreign nations. However, this was revised so it only applied within US or on high seas. Environmental groups argued this change violated ESA and harmed their members' interests who studied these animals abroad. The court held that plaintiffs lacked "actual injury" as they failed to demonstrate immediate plans for return trips to affected areas; thus, their harm was speculative rather than imminent - a requirement for Article III standing. Additionally, since no specific action violating ESA had been identified and challenged directly but instead an overall policy change was being contested without any particular application causing direct harm – there wasn’t enough “causation” or “redressability”. This landmark decision clarified requirements for individuals or groups seeking legal standing in environmental cases.

In the dissenting opinion for Manuel Lujan, Jr., Secretary of the Interior v. Defenders of Wildlife et al., Justice Blackmun disagreed with the majority's interpretation of standing under Article III. He argued that the plaintiffs had a sufficient personal stake in preserving endangered species abroad to establish injury-in-fact and thus meet constitutional requirements for standing. Furthermore, he contended that Congress has broad authority to define injuries and articulate chains of causation which would otherwise be too attenuated through its power to enact statutes creating legal rights. In this case, he believed Congress did so by enacting Section 7(a)(2) of Endangered Species Act (ESA), which requires federal agencies to ensure their actions do not jeopardize endangered species anywhere in world - not just within United States borders as majority held. Therefore, according to him, plaintiffs' inability to observe or study certain animals due their potential extinction caused by U.S.-funded projects overseas constituted an injury-in-fact redressable by court action enforcing ESA provisions.