In Friends of St. Frances Xavier Cabrini Church v. Federal Emergency Mgmt. Agency, Case No. 10-30918, 2011 WL 4435792 (5th Cir. Sept. 26, 2011), the court of appeals ruled that an association comprised of individuals who were current and former parishioners of Cabrini Church, alumni of St. Frances Xavier Cabrini and Redeemer School (Cabrini School), preservationists, architects, citizens and residents lacked standing to assert a claim that the Federal Emergency Management Agency (FEMA) was required under the National Historic Preservation Act (NHPA) to include Holy Cross School campus in a protected Area of Potential Effects (APE) within the meaning of the NHPA. In the aftermath of Hurricanes Katrina and Rita in 2005, Holy Cross School, an all-boys parochial school, applied for, and FEMA granted, public assistance funds to construct a new campus roughly six miles away on the site of Cabrini School, also damaged by the hurricanes. Cabrini Church was a historic site, but the Archdiocese of New Orleans received permission to demolish it after salvaging numerous historically significant objects due to the damage the property sustained. The Archdiocese also received permission to demolish all but one building on the campus of Holy Cross. The association filed suit alleging injury resulting from FEMA’s neglected historic preservation review of the old Holy Cross property. The court ruled that parties complaining of such deficiencies must have a sufficient “geographical nexus” to the property in question and that the association lacked any such nexus, because it existed to protect a property “some six miles away from the Holy Cross campus....” The court also rejected standing for parties alleging mere “procedural deficiencies without any tangible personal injury beyond ‘his and every citizen’s interest in personal application of the Constitution and laws.’”