Cameron Cty v. Port Isabel, 997 F.3d 619

Hurricane Dolly rendered the 16-unit Neptune Apartments in Port Isabel uninhabitable; Cameron County Housing Authority (CCHA) and its wholly owned CHEDC sought federal disaster-recovery funding to rebuild.
LRGVDC conditionally approved a grant for a 26-unit redevelopment but conditioned the award on beginning construction by December 1, 2015.
Plaintiffs delayed seeking rezoning and, after a March 2015 P&Z hearing where residents objected, the Planning & Zoning Commission unanimously recommended denial; Plaintiffs withdrew and revised plans multiple times (26 → 16 → 10 → 4 units).
In the final months, City officials declined to permit the 16- and 10-unit proposals but agreed they would permit four single-family units; LRGVDC refused to accept the 4-unit modification and enforced the December 1 deadline, causing the grant to lapse.
Plaintiffs sued the City and zoning bodies under the Fair Housing Act in November 2017; the district court dismissed the FHA claims for lack of standing (and dismissed the P&Z and City Commission as non-suable entities), and Plaintiffs appealed only the FHA-standing ruling.
The Fifth Circuit reviewed standing de novo and limited the injury Plaintiffs relied on to the total loss of funding on December 1, 2015.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Injury in fact	Plaintiffs say their concrete injury arose when LRGVDC withdrew all funds on Dec. 1, 2015 (loss of ability to rebuild).	City did not dispute that the loss-of-funds on Dec. 1 would be an injury, and Plaintiffs framed the injury that way to satisfy timeliness.	Court accepted Plaintiffs’ characterization that the asserted injury was the total loss of funds on Dec. 1, 2015.
Causation / Traceability	Plaintiffs argue the City’s zoning actions and refusals to issue permits caused LRGVDC to withdraw funding.	City argues the loss was caused by LRGVDC’s deadline and Plaintiffs’ own delays and strategic choices; City even offered approval for four units, which LRGVDC rejected.	Court held the injury was not fairly traceable to the City (third-party and self-inflicted causes); standing fails and dismissal is affirmed.

Lujan v. Defs. of Wildlife, 504 U.S. 555 (1992) (standing elements and burden of proof)
Center for Biological Diversity v. EPA, 937 F.3d 533 (5th Cir. 2019) (injury-in-fact and causation for standing)
United States ex rel. Drummond v. BestCare Lab'y Servs., L.L.C., 950 F.3d 277 (5th Cir. 2020) (scope of issues on appeal)
Williams v. Parker, 843 F.3d 617 (5th Cir. 2016) (de novo review of standing determinations)
Gill v. Whitford, 138 S. Ct. 1916 (2018) (discussion of standing elements)
Bernhard v. Whitney Nat'l Bank, 523 F.3d 546 (5th Cir. 2008) (courts may accept plaintiffs’ own framing of their injury)