In the case of Sierra Club v. Morton, Secretary of the Interior et al., 1971, environmental organization Sierra Club sought a declaratory and injunctive relief against Walt Disney Enterprises' plans to develop a ski resort in Sequoia National Forest. The club argued that such development would cause significant ecological damage and was contrary to public interest. However, they did not claim any personal or organizational harm from the proposed actions. The Supreme Court ruled against Sierra Club stating that it lacked standing because it failed to demonstrate actual injury or threat of specific future harm resulting from Disney's plans - mere interest in an issue was insufficient for legal standing under Article III of Constitution which requires "case" or "controversy". This decision led to changes in how environmental groups approached litigation by emphasizing direct impacts on their members rather than general ecological concerns.

In the dissenting opinion for Sierra Club v. Morton, Justice William O. Douglas argued that natural resources like forests, oceans and mountains should have standing in court — essentially granting them similar rights to people or corporations. He believed that contemporary public concern for protecting nature's ecological equilibrium should lead to the conferral of legal rights upon the environment itself, allowing it to be represented in court by groups like Sierra Club who are dedicated to its preservation. This would allow these entities to sue on behalf of the environment when it is being damaged or threatened by human activity. In his view, this was a necessary step towards preventing environmental degradation and ensuring sustainable development.