Food and Commercial Workers v. Brown Group, Inc., 517 U.S. 544, 12 (1996)

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

Opinion of the Court

controversy," Warth, supra, at 511, our cases have not otherwise clearly disentangled the constitutional from the prudential strands of the associational standing test. Cf. Valley Forge Christian College v. Americans United for Separation of Church and State, Inc., 454 U. S., at 471 ("[I]t has not always been clear in the opinions of this Court whether particular features of the 'standing' requirement have been required by Art. III ex proprio vigore, or whether they are requirements that the Court itself has erected and which were not compelled by the language of the Constitution"); June, The Structure of Standing Requirements for Citizen Suits and the Scope of Congressional Power, 24 Envtl. L. 761, 793 (1994) (noting uncertainty "whether requirements such as [associational] standing are constitutional or prudential in nature"). Resort to general principles, however, leads us to say that the associational standing test's third prong is a prudential one.

There are two ways in which Hunt addresses the Article III requirements of injury in fact, causal connection to the defendant's conduct, and redressability. First and most obviously, it guarantees the satisfaction of these elements by requiring an organization suing as representative to include at least one member with standing to present, in his or her own right, the claim (or the type of claim) pleaded by the association. As Hunt's most direct address to Article III standing, this first prong can only be seen as itself an Article III necessity for an association's representative suit. Cf. Simon v. Eastern Ky. Welfare Rights Organization, 426 U. S. 26, 40 (1976) (the association "can establish standing only as representatives of those of their members who have been injured in fact, and thus could have brought suit in their own right"). Hunt's second prong is, at the least, complementary to the first, for its demand that an association plaintiff be organized for a purpose germane to the subject of its member's claim raises an assurance that the association's litigators will themselves have a stake in the resolution of


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