In the case of United States et al. v. Students Challenging Regulatory Agency Procedures (SCRAP) et al., 1972, the U.S Supreme Court ruled in favor of SCRAP, a group of law students from George Washington University who challenged an Interstate Commerce Commission decision allowing freight rate increases without considering environmental impact. The students argued that this violated their rights under the National Environmental Policy Act (NEPA), which requires federal agencies to consider environmental consequences before making decisions. The government contended that SCRAP lacked standing because they were not directly affected by the rate increase and thus could not sue. However, the court held that anyone who uses forests or other natural resources has standing if those resources are threatened with harm due to a governmental action violating NEPA requirements.

In the dissenting opinion for the United States v. SCRAP case, Justice Rehnquist argued that the majority had significantly broadened standing doctrine in a way that was inconsistent with constitutional and prudential principles. He contended that there should be a logical connection between the status asserted by litigants and their claim of injury, which he believed was not present in this case as it involved an environmental issue affecting everyone rather than specific individuals or groups. Furthermore, he criticized how broadly "injury" was defined here - including aesthetic and environmental harm - arguing this could open floodgates to litigation on any governmental action perceived to cause such damage. Lastly, Rehnquist expressed concern about courts being overwhelmed with cases if they were required to adjudicate claims where plaintiffs have no concrete interest different from general public's.