In the case of Lujan, Secretary of the Interior, et al. v. National Wildlife Federation et al., 1989, the U.S Supreme Court ruled that a party must demonstrate "actual or imminent" injury to have standing in court and cannot rely on a "procedural right." The National Wildlife Federation (NWF) had challenged land use changes by the Bureau of Land Management (BLM), arguing they violated federal law. However, NWF could not prove it was directly harmed by these actions as its members did not use all lands affected but only specific parcels within them. The court found that generalized grievances about government activity were insufficient for legal standing; instead, plaintiffs needed to show concrete harm from specific actions taken by defendants. This ruling clarified requirements for establishing legal standing in environmental cases and emphasized that courts are limited to adjudicating actual disputes between parties rather than addressing broad policy issues.

In the dissenting opinion for Lujan v. National Wildlife Federation, Justice Blackmun argued that the majority's decision was too narrow in its interpretation of standing and judicial review under the Administrative Procedure Act (APA). He contended that by requiring specific injury to an individual party, rather than accepting a general harm done to public lands as sufficient grounds for legal action, the court effectively limited citizens' ability to challenge government actions affecting public resources. Furthermore, he criticized the majority's dismissal of "procedural injury" - i.e., failure by agencies to follow proper procedures before making decisions - as a valid basis for lawsuits. In his view, this undermined one of APA’s key purposes: ensuring transparency and accountability in administrative decision-making processes. Thus, he believed that any citizen should have standing if they can show procedural violations or potential environmental damage due to agency actions.