527 Ass`n of Data Processing Service Org. v. Camp, 397 U.S. 150 (1970); Barlow v. Collins, 397 U.S. 159 (1970). Justices Brennan and White held that only one injury should indeed be required to be maintained. Id., p. 167. In Clarke v.
Securities Industry Ass`n, 479 U.S. 388 (1987), the Court applied a liberalized area of interest. But see Lujan v. National Wildlife Federation, 497 U.S. 871, 885–889 (1990); Air Courier Conf. v. American Postal Workers Union, 498 U.S. 517 (1991). In applying those criteria, after finding that the applicant`s interests were `well protected` by the law in question, the Court proceeded to the merits without examining whether the interests relied on were actually protected. Arnold Tours v. Camp, 400 U.S.
45 (1970); Investment Company Institute v. Camp, 401 U.S. 617 (1971); Boston Stock Exchange v State Tax Comm`n, 429 U.S. 318, 320 n.3 (1977). Almost at the same time, the Court also liberalised the requirement of maturity in the review of administrative acts. Gardner v. Toilet Goods Ass`n, Inc., 387 U.S. 167 (1967); Abbott Laboratories v. Gardner, 387 U.S.
136 (1967). See also National Credit Union Administration v. First National Bank & Trust Co., 522 U.S. 479 (1998), in which the court held that a bank had the power to challenge an agency decision extending the role of employer-credit union to credit unions of several employers, even if such a union was limited by law if they could be groups with a common professional relationship or association. The court ruled that a plaintiff did not have to prove that the purpose of Congress was to protect his interests. It is sufficient that the interest invoked “probably lies in the sphere of the interests to be protected. by the statutes. Id. to 492 (inner and omitted quotation marks). But the court split 5-4 in the application of the test. See also Bennett v. Speer, 520 U.S. 154 (1997).
465 Gladstone Realtors v. Village of Bellwood, 441 U.S. 91, 99–100 (1979) (“A plaintiff still cannot have standing under the principles of prudential law by which the judiciary seeks to avoid issues of general social importance in the absence of individual rights and to limit access to federal courts to litigants best placed to: to make a specific claim”). A person seeking an injunction or declaratory relief “must prove a very substantial possibility of future harm in order to have standing.” Nelsen v. King County, 895 F.2d 1248, 1250 (9th Cir. 1990), cert. denied, 112 p. C. 875 (1992). 529 Sierra Club v. Morton, 405 USA 727, 734 (1972), Furthermore, according to the Court, once a person finds that he is entitled to seek judicial review of a special infringement action, he may invoke the public interest as a `representative of the public interest` as a `private Attorney General`, so that he may not only challenge the act which infringes it, but all acts, including their action giving rise to infringement.
Id., pp. 737–738, referring to Scripps-Howard Radio v. FCC, 316 U.S. 4 (1942); FCC v. Sanders Brothers Radio Station, 309 U.S. (1940). See also Gladstone Realtors v. Village of Bellwood, 441 U.S. 91, 103 n. (1979); Havens Realty Corp. v. Coleman, 455 U.S.
363, 376 n.16 (1982) (referring to this party`s ability to represent the interests of others). An applicant must have suffered “impairment of a legally protected interest” that meets two additional criteria: (1) it is “concrete and detailed”; and (2) it is “actual or imminent,” as opposed to “presumed or hypothetical.” Lujan, 504 U.S. to 560. It does not have to be economic harm, but it has to be something that directly affected the plaintiff. 426 Summers v. Earth Island Institute, 129 pp. Ct. 1142, 1151 (2009) (an environmental group was denied an opportunity to make representations to the United States Forest Service on a Forest Service lawsuit that was dismissed for lack of specific violation). If, on the other hand, a party has successfully asserted a lawsuit, the threat to assert this right will result in separate legal damages. Salazar v. Buono, 559 U.S.
___, No. 08–472, Slip op. cit. at 8 (2010) (majority opinion) (“A party who obtains a judgment in his or her favour acquires a “judicially recognizable” interest in ensuring the enforcement of that judgment”).