id	author	title	date	pages	extension	mime	words	sentence	flesch	summary	cache	txt
cjel-3604	Chin, Courtney	Standing Still: The Implications of Clapper for Environmental Plaintiffs’ Constitutional Standing	2019	36	.pdf	application/pdf	13704	672	59	and the proactive nature of most environ- mental lawsuits.’”8 It further asserted that “many litigants who were granted standing in Supreme Court cases from the past decade could not have satisfied [Clapper’s] standard,” cit- ing cases like Monsanto Co. v. Geerston Seed Farms and Mas- sachusetts v. EPA as examples.9 Similarly, others have pointed out that Clapper requires environmental plaintiffs “to chal- lenge discrete actions rather than overarching government regulations or policy statements. . . . I then turn to Susan B. Anthony v. Driehaus, a post- Clapper Supreme Court standing decision, and argue that the Court’s use of the “substantial risk” standard confirms my the- sis.	cache/cjel-3604.pdf	txt/cjel-3604.txt