In the case of Warth et al. v. Seldin et al., a group of low-income individuals and non-profit organizations from Rochester, New York sued the town of Penfield for its zoning laws which they claimed effectively prevented construction of low-cost housing, thereby excluding them from living in the town. The plaintiffs argued that these zoning ordinances violated their constitutional rights and federal statutes by promoting racial and economic discrimination. However, the Supreme Court ruled against them stating that they failed to demonstrate sufficient connection between their situation and Penfield's zoning practices - essentially ruling that they lacked standing to sue because they could not prove direct harm caused by those policies. The court also held that non-profit organizations did not have standing merely on grounds of representing certain groups without showing some direct injury or threat to their organizational purpose.

In the dissenting opinion for Warth et al. v. Seldin et al., Justice William O. Douglas argued that the majority's decision to dismiss the case due to lack of standing was incorrect and overly narrow in its interpretation of who can bring a lawsuit under these circumstances. He contended that both low-income individuals seeking affordable housing and neighboring communities affected by exclusionary zoning practices should have legal standing, as they are directly impacted by such policies. Furthermore, he criticized the court's unwillingness to address systemic issues related to racial segregation and economic inequality perpetuated by discriminatory zoning laws, asserting that judicial intervention is necessary when political processes fail marginalized groups.