A More Lenient Standing Analysis for Organizational Plaintiffs

March 10, 2025  |  New York Law Journal

The Second Circuit's decision in Do No Harm v. Pfizer Inc. is a significant ruling for organizations pursuing civil rights cases. The court held that an organization’s lack of standing to secure a preliminary injunction does not require dismissal of the entire case since a higher evidentiary burden applies for evaluating standing for purposes of a preliminary injunction than for dismissal. In their latest article for the New York Law Journal, “A More Lenient Standing Analysis for Organizational Plaintiffs,” Morvillo Abramowitz partners Edward M. Spiro and Christopher B. Harwood analyze how the Second Circuit clarified the evidentiary standards for organizational standing, particularly when plaintiffs seek to protect member anonymity during the pleading stage.

A More Lenient Standing Analysis for Organizational Plaintiffs