Clapper v. Amnesty International USA (2013)
Amnesty International challenged the FISA Amendments Act, arguing its members' communications could be monitored without notice. The Supreme Court rejected standing because the alleged injury relied on speculation about how independent actors would behave.
The case was dismissed without reaching the merits of the surveillance law.
Established that standing cannot rest on speculative chains of third-party conduct, a principle the Ninth Circuit applied directly here.
Callahan's opinion quoted the same third-party speculation logic from Clapper to reject California and Giffords' standing theories.
