Moreover, the Supreme Court has made clear that courts err by characterizing as a question of “standing” the issue of whether a particular litigant is authorized to bring a substantive claim under a statute. See Lexmark Int’l, Inc. v. Static Control Components, Inc., — U.S. —, 134 S.Ct. 1377, 1387, 188 L.Ed.2d 392 (2014) (“Although we admittedly have placed [the zone-of-interests] test under the ‘prudential’ [standing] rubric in the past, it does not belong there .... Whether a plaintiff comes within ‘the “zone of interests” ’ is an issue that requires us to determine, using traditional tools of statutory interpretation,. whether a legislatively conferred cause of action .encompasses' a particular plaintiffs claim.” (citation omitted)); Bond, 564 U.S. at 218-19, 131 S.Ct. 2355 (<HOLDING>). Thus, the question that courts have
holding that tennessee electric power co v tva 306 us 118 59 sct 366 83 led 543 1939 had improperly conflated the merits question of whether the plaintiff inthat case had a cause of action with the justiciability question of whether the plaintiff had standing to raise a federalism challenge holding that plaintiff had standing where the beneficiary of a letter of credit had assigned to plaintiff its cause of action for wrongful dishonor of the letter of credit holding that the question whether a cause of action exists is not a question of jurisdiction and therefore may be assumed without being decided holding that the question of whether police had a reasonable basis for finding that a third party had authority to consent to search is a question of law holding that by its plain meaning section 1367 overrules clark v paul gray inc 306 us 583 59 sct 744 83 led 1001 1939 in which the supreme court held in a nonclass action case that each plaintiffs claim must satisfy the amount in controversy requirement