The Supreme Court has stated that a plaintiff must be able to establish that he had direct contact with the challenged government conduct. In Valley Forge Christian College v. Americans for Separation of Church and State, 454 U.S. 464, 102 S.Ct. 752, (1982) a group called "Americans United For Separation of Church and States" (Americans United) challenged the federal government's cost-free transfer of 77 acres of land near Philadelphia to the Valley Forge Christian College.  Americans United, which described itself as a non-profit organization composed of 90,000 taxpayer members, learned of the transfer through a news release and filed suit.  The district court dismissed the complaint on the ground that the plaintiffs lacked standing as taxpayers, and on the ground that plaintiffs had failed to alleged "any actual or concrete injury beyond a generalized grievance common to all taxpayers." 454 U.S. at 469, 102 S.Ct. at 757.
The Court of Appeal for the Third Circuit unanimously agreed that the plaintiffs lacked standing as taxpayers, but a majority held that plaintiffs had standing "merely as 'citizens,' claiming 'injury in fact' to their shared individuated right to a government that 'shall make no law respecting the establishment of religion."  454 U.S. at 470, 102 S.Ct. at 757, quoting from the Third Circuit's opinion at 619 F.2d 252, 262 (3rd Cir. 1980).
The Supreme Court rejected this "unusually broad and novel view of standing" (454 U.S. at 470, 102 S.Ct. at 757) and affirmed the requirement that essential to standing is a showing of "an actual injury redressable by the court."  Jd., at 472, 102 S.Ct. at 758 (citations omitted).  In rejecting the Court of
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