By Andrew H. Perellis and Patrick D. Joyce

Supreme CourtSeyfarth Synopsis: U.S. Supreme Court: mere violation of a statute creating a private right of action is not itself sufficient to satisfy the standing requirement under Article III’s “case or controversy.” To establish federal jurisdiction a plaintiff must still establish an “injury in fact” that is both

By Craig B. Simonsen and Jeryl L. Olson

The District Court of Idaho, in Idaho Conservation League v. Atlanta Gold Corporation, No. 11-CV-161 (January 9, 2012), recently granted summary judgment to allow standing in a citizen’s suit. In the case, Atlantic Gold Corporation (Defendant) held a U.S. Environmental Protection Agency (EPA) National Pollutant Discharge