Brown v. County of Erie
This appellate case concerns the standing of petitioners, Building and Construction Trades Council of Buffalo and Vicinity and Operating Engineers Local 17 Training Fund, to challenge a public works contract awarded by Erie County to Tom Greenauer Development, Inc. Petitioners argued the contract was invalid due to Greenauer's non-compliance with a local law requiring a certified worker training program. The Supreme Court's decision granting the petition was reversed on appeal, with the appellate court concluding that petitioners lacked standing. The court held that petitioners failed to demonstrate an actual injury in fact distinct from the general public, deeming their alleged harm speculative and insufficient for associational or organizational standing. A dissenting opinion argued that petitioners did have standing, emphasizing the local law's intent to promote apprenticeship programs and the direct impact of the county's non-compliance on petitioners' ability to participate.