St. James Parish, Louisiana v. Inclusive Louisiana, By and Through Their Members, et al.

Article III Standing Environmental justice activist organizations, acting as the Plaintiffs and purporting to have suffered harm as the result of private actions by private landowners, lack standing to sue governmental entities that merely issue approvals for land use but do not perform the allegedly harmful acts. Article III establishes the bar for a plaintiff to have standing to access a court to proceed against a defendant. This Court announced the three elements of standing, the second of which requires “a causal connection between the injury and the conduct complained of – the injury has to be ‘fairly ... trace[able] to the challenged action of the defendant, and not ... th[e] result [of] the independent action of some third party not before the court.’” Lujan v. Defenders of Wildlife, 504 U.S. 555, 560 (1992). St. James Parish, the Petitioner, issues approvals to thirdparty landowner applicants for various uses, including industrial development, but ultimately does not control what actions the applicants take on their land. The question presented is: Can a governmental entity “significantly contribute” to a plaintiff’s alleged harms in a manner sufficient to support Article III standing when the governmental entity merely issues non-coercive land use decisions allowing independent actions by third parties not before the court to take the actions that lead to and cause the plaintiffs’ alleged harms?

Statute of Limitations The Plaintiffs’ private cause of action alleges that St. James Parish, the Petitioner, engaged in a “longstanding pattern and practice of racially discriminatory land (i)