 The Sierra Club's legal interest in the case, according to the Court, seemed to be relying on a “zone of interests” test that Justice Douglas had announced in two cases decided on March 3, 1970.Declining to clarify the meaning of “zone of interests”, the Court reasoned that broadening the categories of injury is different “from abandoning the requirement” that plaintiffs themselves actually be injured.The Sierra Club had no standing to sue because it did not allege it was itself in any way injured by Disney's ski resort.