specially:
I concur and join the opinion for the court. I write separately to note one additional factor'in support of our decision that Harris has failed to satisfy the final prong (relating to any hinderance to the third party’s ability to protect the right) of the exception to the general rule against third-party standing. While there may be amongst Harris’ allegations some implicit suggestion that prison employees’ fear of ádverse personnel action hinders their assertion of the right, such possibility, even if not remote, is mitigated by the fact that the Parole Board itself has both an interest, a duty and ample means to obtain all the information that would be of assistance in their decision-making process. Thus, I she no realistic risk that useful information is overlooked, or anybody’s right to provide such information is infringed.
KRAVITCH, Circuit Judge,dissenting, in which HATCHETT, Circuit Judge, and CLARK, Senior Circuit Judge, join:
I agree with the majority opinion as it outlines the law of standing. I disagree, however, with the majority’s application of the law to the facts of this case. The central purpose of the standing requirement, as expressed by the majority, is “to ensure that the parties before the court have a concrete interest in the outcome of the proceedings such that they can be expected to frame the issues properly.” Majority opinion at 1125. In my view, Harris’s strong interest in having recommendations made to the parole board on his behalf ensures that he would properly frame this issue and vigorously advocate the First Amendment rights of the prison employees.
To have standing, a litigant must satisfy both the requirements of Article III of the Constitution which mandates that a case or controversy be presented, and prudential *1126considerations which are designed to properly limit the role of the federal courts. Secretary of State of Md. v. Joseph H. Munson Co., Inc., 467 U.S. 947, 956, 104 S.Ct. 2839, 2846 (1984). The majority apparently concedes that Harris satisfies the Article III requirements, so our disagreement stems from the application of the prudential restraints against third-party standing to Harris. A litigant asserting third-party standing must demonstrate that he or she has suffered an injury-in-fact, that a close relationship with the third party exists and that there is some impediment to the third party’s ability to assert his or her own rights.1 Powers v. Ohio, 499 U.S. 400, 409-12, 111 S.Ct. 1364, 1370-71 (1991). I conclude that Harris satisfies each of those requirements and has third-party standing to litigate the First Amendment rights of the prison employees. Therefore, I respectfully dissent.
I.
The majority determines that Harris has not alleged injury-in-fact. I disagree. Harris’s complaint states: “I have asked employees that know me to write letters to the parole Board for me, but they say that they are ordered not to write any such letters and could face termination if they do so.” As the majority recognizes, we are required to construe Harris’s complaint in his favor for two distinct reasons. In “ruling on a motion to dismiss for want of standing, both the trial and reviewing courts must accept as true all material allegations of the complaint, and must construe the complaint in favor of the complaining party.” Warth v. Seldin, 422 U.S. 490, 501, 95 S.Ct. 2197, 2206, 45 L.Ed.2d 343 (1975). Further, complaints drafted by pro se litigants are held to “less stringent standards than formal pleadings drafted by lawyers.” Haines v. Kerner, 404 U.S. 519, 520, 92 S.Ct. 594, 596, 30 L.Ed.2d 652 (1972). The majority holds that because Harris has not specifically alleged that there are employees who would write letters for him if the policy were not in place, he has not alleged injury-in-fact. However, the purpose of reading pro se complaints in a less stringent fashion is to prevent dismissals in cases such as this where, construing Harris’s complaint in his favor, it is implicit that prison employees wish to write letters on his behalf but are prevented from doing so by the policy.2 In my view, Harris alleges sufficient injury-in-fact in claiming that prison employees are prevented from writing to the parole board on his behalf. See United States v. Students Challenging Regulatory Agency Procedures (SCRAP), 412 U.S. 669, 689 n. 14, 93 S.Ct. 2405, 2417 n. 14, 37 L.Ed.2d 254 (1973).
II.
I also disagree with the conclusion of the majority that Harris lacks a sufficiently close relationship to the prison employees to be granted third-party standing. The requirement of a close relationship between the parties is designed to ensure that the litigant “is fully, or very nearly, as effective a proponent of the right” as the third party. Singleton v. Wulff, 428 U.S. 106, 115, 96 S.Ct. 2868, 2874, 49 L.Ed.2d 826 (1976). The relationship of the litigant and the third party is examined in the context of the right that the litigant is seeking to assert. Thus, in Powers, when the Supreme Court recognized a close relationship between litigants and veni-repersons such that a defendant had third-party standing to assert the rights of prospective jurors, it did not hold that this close relationship existed generally; rather, it stated that on the issue of discrimination against *1127prospective jurors, the litigants’ and venire-persons’ interests were aligned. 499 U.S. at 414-16, 111 S.Ct. at 1373. In this case, Harris has established that he has a close relationship with the prison employees in that their interests in litigating the employees’ right to directly communicate with the parole board are aligned.
Contrary to the contention of the majority that Harris does not claim that he enjoys a substantial relationship with the prison employees, Harris’s complaint states that the policy, “is ridiculous because those who work with us daily, supervise us, etc., are the ones that KNOW the person I am. If those who KNOW us aren’t permitted to write letters in our behalf then who else knows us and could do so? ” Harris asserts a relationship with prison employees that is arguably closer than others in which third-party standing has been granted. See Powers v. Ohio, 499 U.S. 400, 111 S.Ct. 1364, 113 L.Ed.2d 411 (1991) (criminal defendant may assert equal protection rights of prospective jurors); Craig v. Boren, 429 U.S. 190, 97 S.Ct. 451, 50 L.Ed.2d 397 (1976) (vendor of beer has standing to assert the equal protection rights of males between 18 and 20). Harris has alleged a relationship with the prison employees that would justify third-party standing on this issue.
The majority determines that Harris, because he is a prison inmate, necessarily has an adversarial relationship with prison employees. The basis for the majority’s conclusion is unclear. The only evidence in the record that reflects the relationship between inmates and prison employees is the assertion in Harris’s complaint, quoted above, that Harris had a close relationship with the prison employees.3 Although in certain contexts inmates and prison employees would be in an adversarial relationship, here there is a congruence of interests between the rights of the employees to communicate directly with the parole board and Harris’s desire that prison employees be permitted to write on his behalf.
III.
The third factor to be considered in deciding whether to grant third-party standing is whether there is some hindrance to the third party’s ability to protect his or her own interests. Harris’s complaint also demonstrates that there might exist impediments to the prison employees’ ability to litigate their own claim. The employees approached by Harris about writing letters on his behalf responded that if they wrote such letters they could be terminated. The fear of adverse job action is a barrier to litigating this claim. Additionally, the Court noted in Powers that practical considerations such as “the small financial stake involved and the economic burdens of litigation,” present considerable barriers to litigation because there may be “little incentive to set in motion the arduous process needed to vindicate” the right. 499 U.S. at 415, 111 S.Ct. at 1373. In this case, as in Powers, the third parties, here prison employees, face considerable obstacles and have little incentive to induce them to assert their rights. The majority states that the only reason that it can fathom for the failure of the prison employees to challenge the policy is that they support the policy.4 I have suggested two other reasons.
*1128IV.
Harris has alleged facts sufficient to satisfy all of the constitutional and prudential standing requirements. Accordingly, I would hold that the district court had jurisdiction to consider the claim on the merits.
. I do not address the issue of whether Harris should be entitled to the less stringent standing requirements sometimes afforded those asserting First Amendment claims, as I conclude that even under the stricter standard Harris has standing.
. Further, to the extent that Harris’s complaint is not clear with respect to this allegation, a remand for factual finding would determine whether there are prison employees that want to write letters on Harris's behalf. In this case, because standing was not raised by the parties below, fact-finding was not conducted. As the Supreme Court has noted, “it is within the trial court's power to allow or to require the plaintiff to supply, by amendment to the complaint or by affidavits, further particularized allegations of fact deemed supportive of plaintiff's standing." Warth v. Seldin, 422 U.S. at 501, 95 S.Ct. at 2207. The district court did not ask the parties for additional evidence before it concluded that Harris had standing. If further evidence is needed, a remand is the proper solution.
. The appellants, in contending that Harris should not be granted standing, do not argue that the inmate-prison employee relationship was adversarial. Further, assuming that the majority would admit that' an employee could desire to write a letter on Harris's behalf, it is unclear why this relationship would be categorized as adversarial in this context. To the extent that the majority believes that an adversarial relationship exists, because there is no evidence in the record to support such a conclusion, the proper solution would be to remand this case so that evidence could be presented on this issue.
. The majority reasons that perhaps the prison employees have not challenged the policy because they support it, further speculating that the employees view the policy as protecting them from disgruntled prisoners. This seems unlikely .in view of the fact that the prison employees already indirectly .communicate with the parole board through documents such as performance and work reports, program involvement and disciplinary reports forwarded to the board when the inmate is considered for parole. The current policy only forbids direct communication. If the employees could be subject to such hostility from inmates as a result of direct communication, they *1128could equally be subject to hostility based upon other reports.