National Park Service v. National Trust for Historic Preservation in the United States

Majority reasoning

The Court held that the government is likely to win because the Trust's only claimed injury—one member's distaste for the ballroom's "scale," "height," and "massing"—amounts to mere offense or disagreement, which longstanding precedent says cannot support Article III standing. The majority distinguished environmental cases like Laidlaw and Summers, where plaintiffs alleged concrete interference with actual use of a river or forest (fishing, swimming, camping), from this case, where the member's only injury is having to look at a building she dislikes. The majority rejected the argument that the member's professional expertise in historic preservation creates a special standing exception, noting that standing doctrine does not turn on the intensity or specialness of a litigant's interest. On the equitable factors, the majority found the government would suffer irreparable harm from the injunction based on multiple national security declarations describing the ballroom's height and mass as necessary to shield an underground military installation, and concluded these harms far outweigh the Trust's claimed aesthetic injury.

Dissent reasoning

Chief Justice Roberts, joined by Justices Sotomayor, Kagan, and Jackson, argued that the construction is likely unlawful because a federal statute requires express congressional authorization for new buildings on federal park land in Washington, D.C., and neither appropriations statute the government cites provides that authorization. On standing, the dissent argued that the member's aesthetic injury is concrete and particularized because she has a documented, decades-long professional and personal interest in physically viewing and studying historic buildings like the White House, comparable to the recognized aesthetic interest in observing a specific animal species or river recognized in prior environmental standing cases. The dissent rejected the majority's characterization of her injury as "mere offense," contending that the primary way people appreciate a historic building is by looking at it, so requiring additional physical use (like swimming or camping) to establish standing does not meaningfully distinguish her situation from the environmental plaintiffs found to have standing in Laidlaw. The dissent concluded that by rejecting standing here, the majority allows the executive branch's likely infringement on Congress's spending and property authority to continue unchecked.