How has the Court considered ownership and possession in the context of the Article III standing test?

At the same time, we have been careful to acknowledge that while ownership and possession generally may provide evidence of standing, it is the injury to the party seeking standing that remains the ultimate focus. It is because of the lack of proven injury that we have, for example, denied standing to "straw" owners who do indeed "own" the property, but hold title to it for somebody else. Such owners do not themselves suffer an injury when the property is taken. See United States v. 500 Delaware Street, 113 F.3d 310, 312 (2d Cir.1997).

Acknowledging that "[t]he word 'possession' drips with ambiguity," Mercado, 873 F.2d at 644 (quoting City of New York v. Hall, 139 F.2d 935, 936 (2d Cir.1944)), we have similarly held that where a mere custodian has possession, it is only a "naked claim of possession" and does not thereby impart Article III standing. He or she has not demonstrated injury sufficient to satisfy the Article III standing test. See id. at 645.

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