American Bottom Conservancy v. U.S. Army Corps of Engineers

Dist. Ct erred in dismissing plaintiff’s lawsuit on lack of standing grounds, where said lawsuit sought to invalidate permit issued by defendant-U.S. Corps of Engineers that granted defendant-landfill owner ability to use for owner’s existing landfill wetland soil located near park. Plaintiff’s allegation that three of its members would have diminished pleasure in viewing wildlife from park if wetlands were destroyed is sufficient to confer standing. Moreover, plaintiff’s success in instant lawsuit would eliminate probable injury to plaintiff’s members from proposed landfill site at same wetlands at issue in instant permit. Fact that Dist. Ct. might make future ruling that any bad effects of proposed landfill would be immaterial on permit validity issue is insufficient to defeat plaintiff's standing to bring instant case.