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Dean Nichol and Professor Pierce have presented two interesting views of Lujan v. Defenders of Wildlife.' Both read this case as the first instance in which the U.S. Supreme Court has limited the power of Congress to confer standing on individuals to sue. Dean Nichol views this limitation as part of Justice Scalia's "broader agenda" of reducing the role of the judiciary in government policymaking.2 Professor Pierce views it as part of a different project: Reducing the role of Congress in government policymaking.3 Both Nichol and Pierce, as devotees of grand theory, are interested in analyzing Scalia's "agenda," however described. They view Defenders as a fundamental change in the Court's standing jurisprudence, in part because of the symbolism they and their fellow detractors impart to the decision. In contrast, I am apparently a miniaturist, at least when it comes to the possibility of grand theories and "broader agendas." I say this because I do not read Defenders as a major departure in the law of standing. The case merely applied a settled principle-that the case or controversy requirement in Article III of the Constitution requires a

Defending Defenders: Remarks on Nichol and Pierce