The D. C. Circuit says yes. Last week’s article (on the blog Circuit Splits) is here. The article analyzes how the D.C. Circuit decision Grocery Manufacturers Association v. E.P.A. creates a circuit split as to whether prudential standing is jurisdictional. The dissent in the case relies significantly on Match-E-Be-Nash-She-Wish Band of Pottawatomi Indians v. Patchak.