Toby Stover v. National Park Service et al.

Summary

The United States District Court for the District of Columbia dismissed Toby Stover's challenge to the National Park Service's cashless payment policy for lack of Article III standing. The court held that her past denial of entry did not support declaratory or injunctive relief and that her stated desire to return to the site did not establish an imminent or concrete injury. The court also concluded that alleged statutory rights under the Administrative Procedure Act and Legal Tender Statute could not substitute for a concrete injury in fact.

Holdings

1. Stover did not plausibly allege an imminent injury because she alleged no concrete plans to revisit Hyde Park or another National Park Service site and instead expressed only a generalized desire to visit sometime in the future.
2. Stover did not plausibly allege a concrete injury because the cashless policy did not prevent her from visiting the site or paying the entrance fee electronically; her objection to electronic payment amounted only to an injury in law.
3. Stover's decision to avoid visiting Hyde Park because she objected to paying electronically was self-inflicted harm and did not satisfy the injury-in-fact requirement.
4. Alleged statutory standing under the Administrative Procedure Act or the Legal Tender Statute cannot substitute for the concrete injury required by Article III.

Questions Presented

1. Whether Stover plausibly alleged an injury in fact sufficient to establish Article III standing for declaratory and quasi-injunctive relief challenging the National Park Service's cashless admission policy.
2. Whether an alleged statutory violation under the Administrative Procedure Act or the Legal Tender Statute, without a concrete real-world injury, independently establishes Article III standing.

Disposition

dismissed