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Article III of the Constitution limits the jurisdiction of federal courts to 'actual cases or controversies between proper litigants.' Fla. Audubon Soc'y v. Bentsen, 94 F.3d 658, 661, 320 U.S. App. D.C. 324 (D.C. Cir. 1996). To establish constitutional standing, plaintiffs 'must have suffered or be imminently threatened with a concrete and particularized injury in fact that is fairly traceable to the challenged action of the defendant and likely to be redressed by a favorable judicial decision.' Lexmark Int'l, Inc. v. Static Control Components, Inc., 134 S. Ct. 1377, 1386, 188 L. Ed. 2d 392 (2014); see also Lujan v. Defenders of Wildlife, 504 U.S. 555, 560, 112 S. Ct. 2130, 119 L. Ed. 2d 351 (1992).


The requirements for standing differ where, plaintiffs seek to enforce procedural (rather than substantive) rights. When plaintiffs challenge an action taken without required procedural safeguards, they must establish the agency action threatens their concrete interest. Fla. Audubon Soc'y, 94 F.3d at 664. It is not enough to assert 'a mere general interest in the alleged procedural violation common to all members of the public.' Id. Once that threshold is satisfied, the normal standards for immediacy and ...

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