Sierra Club V. Morton (1972)

Abstract

In 1965 the Sierra Club brought suit against the United State Department of the Interior to protect Mineral King valley in the Sierra Nevada Mountains of California from the development of a planned ski resort by the Walt Disney Corporation. As the case progressed, the chief issue in controversy proved to be the preliminary question of whether the Sierra Club had standing to sue. Rather than alleging that the club or its individual members had a specific interest in Mineral King arising from their use of the valley, the petitioners sued on behalf of the valley, claiming that the Sierra Club had “a special interest in the conservation and sound maintenance of the national parks, game refuges, and forests of the country,” and therefore should be given standing to intervene on behalf of the true party in interest—the Mineral King valley itself. The District Court issued a preliminary injunction against the development, but this decision was reversed by the Court of Appeals, which held that the Sierra Club lacked legal standing to maintain the action because it had not alleged individualized harm to itself or its members.