In Summers v. Earth Island Institute, the United States Supreme Court held that environmental groups lost their standing to challenge federal agency regulations after they settled their claims with the agency. The environmental groups challenged U.S. Forest Service rules exempting salvage timber sales of less than 250 acres from an otherwise applicable notice, comment and appeals process, on grounds that the rules violated the Forest Service Decision Making and Appeals Reform Act. A California Federal District Court and the Ninth Circuit Court of Appeals previously held that the environmental groups had standing to pursue their facial challenges to the rules even though the groups had settled their challenges regarding the application of the rules to the salvage sale at issue in the lawsuit. Justice Antonin Scalia, who authored the Court`s opinion, disagreed. According to Justice Scalia, the groups failed to demonstrate that one of their members would imminently suffer a concrete and specific injury-in-fact — a mandatory requirement for Article III standing. Justice Breyer disagreed in his dissent, stating that he believed that affidavits by members of the environmental groups established a ``reasonable likelihood`` that a member would suffer harm in the near future.