"Standing is the determination of whether a specific person is the proper party to bring a matter before the courts for adjudication." Landrith v. Bank of New York Mellon, 2013 WL 739427, *3 (D. Kan. March 4, 2013) (citing Allen v. Wright, 468 U.S. 737, 750-51 (1984) (quoting Warth v. Seldin, 422 U.S. 490, 498 (1975). The fact that a party has standing to bring a claim does not mean he or she is automatically entitled to recover that claim on the merits.
Blue Cross presents two separate standing arguments. First, it contends that the plaintiff lacks constitutional standing, as defined in cases such as Landrith v. Bank of New York Mellon, No. 12-2352-EFM, 2013 WL 789427, at *3 (D. Kan. March 4, 2013), since he was not the person who suffered the alleged injury. That is, it contends that any injury, and hence the right to sue, belongs solely to Marsha Burton. Second, Blue Cross argues that even if Doug Burton had constitutional standing, he lacks standing under ERISA.