As most of us know, the Georgia Supreme Court in June issued its decision in Republican Nat’l Comm. v. Eternal Vigilance Action, Inc., No. S25A0362, 2025 WL 1633792 (Ga. June 10, 2025), addressing associational standing in Georgia.

For anyone dealing with the implications of that decision in a zoning matter, do not overlook the “dependent standing” doctrine set forth in Lindsey Creek Area Civic Association v. Consolidated Government of Columbus, 249 Ga. 488 (1982).

In that case, the Georgia Supreme Court held that civic associations have standing if “they are joined by individual plaintiffs who have standing[.]”  Accordingly, the relevant inquiry for dependent standing is the standing of the individual property owner appearing as plaintiff.  If the association is joined by a plaintiff with standing, the association has standing too.

The Georgia Supreme Court expressly acknowledged that “[n]ormally the standing of one party is not dependent upon the standing of another party[,] [n]evertheless, in zoning cases we find this ‘dependent standing’ preferable to (a) detailed inquiry as to the membership of the civic association to determine its independent standing, or (b) requiring those individual property owners who have standing to bear the entire burden of opposing the rezoning.”

Lindsey Creek is still good law to be utilized in zoning cases.