This Essay, prepared for a roundtable conference of administrative law scholars, considers the implications of the Supreme Court’s most recent standing decision, Clapper v. Amnesty International, for claims alleging risk-based, or “probabilistic,” injury. Three years before Clapper, in Geertson Seed Farms v. Monsanto, the Court seemed to open the door to such claims by testing the plaintiff’s claim of imminent injury against a test that required the plaintiff to show a “substantial risk” of injury. By contrast, Clapper applied a tougher-sounding test, requiring the plaintiffs in that case to show that their injury was “certainly impending.” Nevertheless, the Court conceded that in the recent past it had applied the “substantial risk” test.The ambiguity caused by Clapper matters because modern regulatory styles – shorthanded here as “New Governance” – often aim at reducing risks of harm to the public. Indeed, such regulation often attempts to attain that goal not through command-and-control regulation, but instead by incentivizing parties to act in ways that mitigate such risks. Both of these characteristics of New Governance regulation make it more likely that regulatory beneficiaries complaining of government mis-regulation will assert probabilistic injury claims. Clapper, by casting at least some doubt on the viability of such claims, thus threatens the availability of judicial review to hold government to account when it commits such errors.This Essay argues that Clapper leaves standing doctrine at least theoretically receptive to these types of injury claims. First, the Court expressly conceded that it has applied the “substantial risk” test in the past – it did not reject that precedent. Second, its explanation of why the plaintiffs before it lacked imminent injury leaves the door open for Congress and administrative agencies to create rights that take the form of increased probabilities for good regulatory outcomes. In turn, the deprivation of such probability-based rights constitutes Article III injury. The Essay notes that, twenty years ago, Justice Kennedy wrote an influential concurring opinion in a major standing case, Lujan v. Defenders of Wildlife, in which he recognized congressional power both to create innovative causes of action and to articulate chains of causation that courts might not otherwise recognize. If the Court remains faithful to Justice Kennedy’s statement – which has significant force given his status as the fifth vote for the standing analysis in Defenders – it should be receptive to probabilistic injury claims when Congress or administrative agencies regulate in a New Governance style.