statute can make generalized grievance a particularized injury(See Havens Realty Corp.
–testers had standing because fair Housing Act provided right to truthful information)
-but isn’t this Congress creating an injury? Concern in all these cases is Congress can give standing to anyone
-but is this problem? – Congress can create rights so why can’t create injury?
-if statute says “any person aggrieved” may confer broad standing (See Dept. of Commerce – – voter who could lose state rep because of statistical sampling had standing)
-Contrast Sinkfield v. Kelly – no standing to challenge majority/minority districts b/c no one lived in district; claim is constitutional not statutory
-Fed. Election Commission v. Akins (1998): group of voters has standing to challenge FEC’s failure to treat AIPAC as a “political committee” under Act b/c statute said “any party aggrieved”
-injury is lack of information
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