900 F.3d 250
6th Cir.2018Background
- Michigan’s Habilitation Supports Waiver provided community services to persons with developmental disabilities; in May 2015 Washtenaw County reverted to a single all‑inclusive budget rate, which reduced recipients’ total budgets though not authorized service hours.
- Washtenaw Association for Community Advocacy (WACA) and three named members sued, alleging due process violations from inadequate notice of the budget reductions; plaintiffs sought a preliminary injunction.
- At an evidentiary hearing the district court found WACA had not shown associational standing for its 169 unnamed members and that the named plaintiffs had received administrative hearings and favorable ALJ rulings, undermining irreparable harm for injunctive relief.
- On interlocutory appeal WACA (but not the individual plaintiffs) sought an order requiring fresh notices and hearing rights for its unnamed members; the appeal therefore raised a narrow redressability/standing question.
- The Sixth Circuit affirmed denial of the preliminary injunction, holding an associational plaintiff must show at least one identified member had standing for each claim and each form of relief sought, and the named members lacked standing to obtain the particular injunctive relief requested on appeal because they had already received hearings.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether WACA has associational standing to seek injunctions (fresh notices and hearing rights) for unnamed members | WACA argued an identified member suffered due process injury from deficient notices, so the Association can seek injunctive relief on behalf of members | Defendants argued named members already received administrative hearings and favorable rulings, so WACA cannot show an ongoing injury redressable by the narrow injunction | Denied: an association must show at least one identified member had standing for each claim and each form of relief; named members lacked standing to seek the particular injunctive relief on appeal because their claimed injuries were not ongoing or redressable by that relief |
| Whether prior administrative hearings for named plaintiffs preclude the specific injunctive relief WACA seeks | WACA contended the hearings did not cure the due process defects for unnamed members and an injunction is needed to provide due‑process‑compliant notices and hearings | Defendants maintained that because named plaintiffs already obtained hearings, there was no present injury warranting injunction for the named members, and thus no associational standing to obtain relief for unnamed members | Held: because the named members had already received hearings when the complaint was filed, they were not suffering an actual or imminent injury that the narrow injunction would redress; thus standing for that relief was not established |
| Standard for associational standing in seeking preliminary injunction | WACA argued general associational standing principles suffice if at least one member had suffered injury | Defendants emphasized that standing must be demonstrated for each form of relief and at the preliminary‑injunction stage the plaintiff must show a substantial likelihood of standing | Held: applied Supreme Court precedent requiring an association to identify a member who had standing for each claim and each requested form of relief; preliminary injunctive movant must show a substantial likelihood of standing |
| Effect of district court’s factual finding that unnamed members were not shown to be members of WACA | WACA asserted the district court mischaracterized the membership evidence and that at least some named plaintiffs were dues‑paying members | Defendants relied on district court findings to challenge associational standing | Held: Sixth Circuit noted the district court erred by not crediting uncontradicted testimony that the three named plaintiffs were members, but this error did not change the appellate result; remanded for further proceedings on standing and claims |
Key Cases Cited
- United Food & Commercial Workers v. Brown, 517 U.S. 544 (association has standing if at least one member would have standing to sue)
- Warth v. Seldin, 422 U.S. 490 (associational standing principles)
- Lewis v. Casey, 518 U.S. 343 ("standing is not dispensed in gross")
- DaimlerChrysler Corp. v. Cuno, 547 U.S. 332 (plaintiff must demonstrate standing for each claim and each form of relief)
- Summers v. Earth Island Inst., 555 U.S. 488 (organization must identify member who suffered or would suffer harm)
- Spokeo, Inc. v. Robins, 578 U.S. 330 (injury‑in‑fact requirements for standing)
- Friends of the Earth, Inc. v. Laidlaw Envtl. Servs., Inc., 528 U.S. 167 (associational standing test elements)
- Goldberg v. Kelly, 397 U.S. 254 (due process requires pre‑termination notice and hearing in certain benefit contexts)
- City of Los Angeles v. Lyons, 461 U.S. 95 (standing to pursue damages does not automatically confer standing for particular injunctive relief)