William Langfan v. The Goodyear Tire & Rubber Co., 529 F. App'x 460

Langfan owns commercial property in Benton Township, Michigan; Goodyear leased the site and conducted contamination cleanup under MNREPA Part 201.
In 2004 Langfan's sale efforts revealed contamination; Goodyear took responsibility and performed response activities as part of ongoing remediation.
Goodyear sought an NFA letter from MDEQ; in 2009 it applied and, on January 26, 2010, MDEQ issued an NFA letter stating no further remediation was required based on the submitted information.
Langfan did not receive notice about the consideration of issuing the NFA letter and questioned whether it had any legally binding or substantial legal effect.
MDEQ representatives stated the letter did not constitute an administrative action or final agency decision and did not indicate any binding action under Part 201.
Langfan sued in district court under 42 U.S.C. § 1983 alleging due process violations and abuse of process; the district court dismissed for lack of a protected property interest and absence of a cognizable deprivation.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Standing to challenge the NFA letter	Langfan asserts injury to title and facility designation caused by the NFA.	No causal link between NFA and any cognizable injury; injury would exist regardless of NFA; the cost of litigation is not a standing injury.	Langfan lacked standing; no traceability or redressability.

Valley Forge Christian Coll. v. Ams. United for Separation of Church & State, Inc., 454 U.S. 464 (1982) (standing requires concrete, particularized injury with traceability and redressability)
Lujan v. Defenders of Wildlife, 504 U.S. 555 (1992) (injury must be concrete and actual or imminent)
Friends of the Earth, Inc. v. Laidlaw Envtl. Servs., Inc., 528 U.S. 167 (2000) (standing requires likelihood of redressability)
Fair Housing Council, Inc. v. Village of Olde St. Andrews, Inc., 210 F. App’x 469 (6th Cir. 2006) (injury must be independent of litigation costs)