ple has three elements: (1) the plaintiff must have suffered an "injury in fact:" an invasion of a legally protected interest which is (a) concrete and particularized, and (b) actual and imminent. (2) There must be a causal connection between the activity complained of and the injury. (3) It must be likely that the injury will be redressed by a favorable court decision.
While this would seem to severely limit the ability of Congress to create statutes which prohibit broad categories of behavior, the Court reaffirmed the holding of Warth v. Seldin that the injury required under Article III may exist as a result of a statute. This means that the statute may create rights, whose invasion may trigger standing. The plaintiff must still show that he or she suffered some concrete injury, although this injury may simply be a violation of the rights created by the statute.
As might be deduced from the limitations mentioned above, the citizen suit provisions of the ESA can be said to establish standing for any individual. The
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