The United States Supreme Court has addressed the absolute core requirements of standing under Article III of the U.S. Constitution on several occasions.  However, the Court has not clearly articulated what purpose standing serves relative to Article III’s limitations on the exercise of judicial power to only “cases” or “controversies,” and this has led to major downstream effects in the realm of multi‑plaintiff litigation.  Specifically, the Court has not explained whether standing is meant to ensure (1) that all potential plaintiffs demonstrate that they are properly parties to the same case or controversy before a federal court or (2) that at least one plaintiff can make out a case or controversy before a federal court.  Should courts consider questions of commonality and adequacy in their standing analyses, or should they be analyzed at a later stage?

This Note discusses the history of standing as a doctrine and its interstitial development alongside the Federal Rules of Civil Procedure (FRCP).  It then explores both potential articulations of standing’s purpose through two distinct circuit splits that have arisen in the multi-plaintiff context, examining how those splits are fueled by this overarching confusion about standing’s purpose.  Ultimately, this Note will advocate for the adoption of a barebones conception of standing that aligns with the second purpose outlined above.  It will demonstrate that adopting the barebones conception would resolve both highlighted splits, as well as other issues related to standing.  This will result in less confusion, more equal access to federal courts nationwide, and honor the separation of powers principles that motivated the restraint on judicial power at the core of Article III.