Reference health
Reorganizing Organizational Standing
4/4 checkable references clean · checked 2026-07-22
Every reference with a DOI in the deposited reference list resolved to a known work in Crossref or DataCite at the dated check, and none carried a retraction, withdrawal, or removal notice.
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The 4 checked references that resolve
resolves10.1017/s003060530323043x
<b>Coral ID CD-ROM</b> by John “Charlie” Veron and Mary Stafford Smith (2002), Australian Institute for Marine Science. See http://www.aims.gov.au/coralid for pricing and availability.
The 29 references without a DOI — listed, not checked
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no DOI — not checked2009) (injury found based on expenses incurred because of organization's "need to care for animals
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no DOI — not checkedSo too, because he was white, he was not lied to. Given Havens confirmed that, for organizational standing, "we conduct the same inquiry as in the case of an individual
no DOI — not checkedUpon reaching that conclusion, isolating the injury's genesis becomes tractable. Only one distinction explains HOME's standing and Willis' lack thereof as a tester. That is, HOME counseled Coles and Coles was subsequently, illegally, given information undermining HOME's service. Willis performed no such service. Havens' lie to Coles, then, triggered HOME's injury. 220 But the question remains, why and how? HOME was not seeking to live in Havens' apartment. Nor was HOME the party actually lied to and thus denied truthful information under the Fair Housing Act. Moreover, this construction of the injury does not neatly align with Arlington Heights
no DOI — not checkedHOME's pre-illegality expenses were not its injury "is the Court's denial of standing to the white tester"). The same scholar proffered three alternative explanations for the injury but I find none persuasive. First, HOME was not "obligated to spend more money educating and counseling" individuals after Havens' illegality came to light. Id. at 592. Any counseling it did (or did not) perform after the illegality was purely volitional. Second, it was not injured because it was unable thereafter "to refer clients to [Havens], thus limiting the available choices it could provide clients
no DOI — not checkedPeople for the Ethical Treatment of Animals v. United States Dep't of Agriculture, 797 F.3d 1087, 1100 (D.C
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no DOI — not checked) (individuals were CAAN members). Moreover, the plaintiffs (1) never argued that the organization had standing in its own right (2) alleged injury only via the increased noise and pollution and (3) committed the standing portion of their brief to a discussion of the Board's structure and how it implicated causation and redressability. See id. at 20-23. In addition, most of the (few) Circuit cases discussing CAAN reference the increased noise as the injury
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no DOI — not checkedOrdinarily, if a for-profit is able to make out this showing, it will have also suffered economic injury and standing will be certain. This category, then, is chiefly implicated (and most relevant) for non-profits
no DOI — not checkedBut non-profits are ubiquitous in the mission advancement cases where economic injury is plainly not established. See generally Smith v
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