The decision of the Supreme Court last year in Sierra Club v. Morton¹ generated fears that the recent acceptance of broadened standing in environmental cases might be reversed. In its June 18th decision in United States v. SCRAP, the Court resolved some of the ambiguity inherent in Sierra Club v. Morton in favor of the trend toward liberalized standing requirements. The same day, however, the Tenth Circuit handed down a surprising decision in Natural Resources Defense Council v. Environmental Protection Agency² that may serve as a reminder to environmental lawyers that standing must still be treated with some care in pleadings. For standing in another recent case, see the Comment in this issue on Scientists' Institute for Public Information v. Atomic Energy Comm.