The Rules on Who Can Sue Are Constantly Evolving

In the early 1970s, a group of patients at a non-profit hospital in the District of Columbia accused the hospital's trustees of engaging in financial mismanagement and self-dealing.

The hospital tried to argue that the patients had no right to sue. But the late Gerhard A. Gesell, then a District Court judge, granted the patients legal standing in the case. He said that they had "a sufficient special interest to challenge the conduct of the

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