Plaintiff owns land near a Federal Wildlife Refuge. The Park Service seeks to sell adjoining land for strip-mining. Is the plaintiff likely to lack standing due to prudential standing limits?

Plaintiff owns land near a Federal Wildlife Refuge. The Park Service seeks to sell adjoining land for strip-mining. Is the plaintiff likely to lack standing due to prudential standing limits?

• A. Yes, because the Park Service's mandate includes management and highest and best use of park properties.
• B. Yes, because the plaintiff has a direct economic interest in the sale.
• C. No, because the plaintiff's injury is not concrete.
• D. No, because the sale affects the public interest.

Answer: (A)

The key idea is prudential standing, specifically the zone-of-interests test. Even if a plaintiff has an injury in fact, that injury must fall within the scope of interests that the relevant statute or agency is designed to protect. Here, the Park Service’s mandate is to manage and determine the highest and best use of park properties. That means the statute and the agency’s duties focus on the park lands themselves and their resources, not on private landowners’ economic interests adjacent to the park. A claim grounded solely on the private economic impact of selling adjoining land for strip-mining isn’t the type of harm the Park Service statute is meant to guard against. So the plaintiff’s injury would not be within the zone of interests protected by the Park Service’s mandate, and the plaintiff would lack standing on prudential grounds. If the claim had shown a direct effect on the park’s resources or integrity—i.e., an injury to the park itself—standing might exist. The other options rely on miscasting the reason for standing, focusing on broad public interest or on private economic stake, which don’t determine prudential standing here.

The key idea is prudential standing, specifically the zone-of-interests test. Even if a plaintiff has an injury in fact, that injury must fall within the scope of interests that the relevant statute or agency is designed to protect.

Here, the Park Service’s mandate is to manage and determine the highest and best use of park properties. That means the statute and the agency’s duties focus on the park lands themselves and their resources, not on private landowners’ economic interests adjacent to the park. A claim grounded solely on the private economic impact of selling adjoining land for strip-mining isn’t the type of harm the Park Service statute is meant to guard against. So the plaintiff’s injury would not be within the zone of interests protected by the Park Service’s mandate, and the plaintiff would lack standing on prudential grounds.

If the claim had shown a direct effect on the park’s resources or integrity—i.e., an injury to the park itself—standing might exist. The other options rely on miscasting the reason for standing, focusing on broad public interest or on private economic stake, which don’t determine prudential standing here.