Rivers v. Exec. Dir. of the Utah Dep’t of Envtl. Quality, 2017 UT 64 (Sept. 20, 2017).

In this appeal of an agency action, the supreme court reminded administrative tribunals of their “independent obligation” to assess a party’s standing before reaching the merits.  Conducting an independent review on appeal, the court held that an environmental organization possessed standing as an association, where its director and members made a sufficient showing that their recreational, aesthetic, and other interests in the land would be harmed by the expansion of mining operations in the absence of relief.