Sierra Club v. Perry

The federal district court for the District of Columbia ruled that Sierra Club had associational standing to bring a lawsuit against the Secretary of Energy to compel the promulgation of energy efficiency standards for manufactured housing. The Energy Independence and Security Act of 2007 required that such standards be established by December 19, 2011. The court found that Sierra Club had demonstrated that its members had suffered economic, health, and procedural injuries, and that there was a causal relationship between the Secretary’s inaction and the alleged injuries that would be redressed by promulgation of energy efficiency standards should Sierra Club prevail. The court said it was undisputed and clear that Sierra Club satisfied both of the remaining requirements for associational standing since its members’ interests were germane to the organization’s purpose and the members’ individual participation in the lawsuit was not required.

Sierra Club filed a lawsuit in the federal district court for the District of Columbia seeking to compel Secretary of Energy Rick Perry to establish energy efficiency standards for manufactured housing. Sierra Club alleged that the Secretary of Energy had failed to meet the December 19, 2011 deadline for prescribing such standards set by the Energy Independence and Security Act of 2007 (EISA). Sierra Club said the Secretary had violated EISA and that the failure to promulgate standards constituted an agency action unlawfully withheld under the Administrative Procedure Act.