Note by Ellen Short

Part II of this Note discusses the development of a circuit split in the application of Havens Realty Corp. v. Coleman, the Supreme Court case which defined the element of injury-in-fact in organizational standing cases. Part III explores how the Fifth Circuit strictly limited Article III standing in the noted case. Lastly, Part IV demonstrates how the strict definition of injury created by the Fifth Circuit, coupled with the challenges of associational standing, limits opportunities for recovery in gentrification cases.