Food and Commercial Workers v. Brown Group, Inc., 517 U.S. 544, 8 (1996)

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Cite as: 517 U. S. 544 (1996)

Opinion of the Court


This brings us to the primary question in the case: whether the union has standing to bring this action on behalf of its members.4 Article III of the Constitution limits the federal judicial power to "Cases" or "Controversies," thereby entailing as an "irreducible minimum" that there be (1) an injury in fact, (2) a causal relationship between the injury and the challenged conduct, and (3) a likelihood that the injury will be redressed by a favorable decision. See, e. g., Northeastern Fla. Chapter, Associated Gen. Contractors of America v. Jacksonville, 508 U. S. 656, 663 (1993); Valley Forge Christian College v. Americans United for Separation of Church and State, Inc., 454 U. S. 464, 472 (1982). Supplementing these constitutional requirements, the prudential doctrine of standing has come to encompass "several judicially self-imposed limits on the exercise of federal jurisdiction." See Allen v. Wright, 468 U. S. 737, 751 (1984); see also Flast v. Cohen, 392 U. S. 83, 97 (1968). The question here is whether a bar to the union's suit found in the test for so-called associational standing is constitutional and absolute, or prudential and malleable by Congress.


The notion that an organization might have standing to assert its members' injury has roots in NAACP v. Alabama ex rel. Patterson, 357 U. S. 449, 459 (1958), where the Court noted that for the purpose of determining the scope of the

4 The union also argues that it has standing because it suffered direct injury. The Court of Appeals held that the union lacked standing to assert its direct injury because neither backpay to the employees nor its "catch-all prayer for relief" would redress the union's injury. 50 F. 3d 1426, 1431, n. 7 (CA8 1995). The union argues here that its injury would be redressed because an award of damages to the employees would deter future violations and would facilitate the union's role in assisting its members. In light of our resolution of the associational standing question, we do not have occasion today to address this issue.


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