A number of United States Supreme Court opinions have been important for their development of the doctrine of legal standing in the context of federal law in the United States. Some of those opinions include:
| Case | Year Decided | Holding | Voting |
|---|---|---|---|
| Dred Scott v. Sandford | 1857 | Held that people of African ancestry (whether free or not) were not United States Citizens, and therefore lacked standing to sue. This ruling stood as precedent until the ratification of the Fourteenth Amendment to the United States Constitution. | 7–2 |
| Georgia v. Tennessee Copper Co. | 1907 | States, as quasi-sovereigns, have parens patriae standing to sue for environmental harms, in this case fumes from copper mining.[1] | 9–0 |
| Fairchild v. Hughes | 1922 | Held that a New York resident (whose state had women's suffrage) lacked any particularized standing to challenge alleged state-level of the ratification of the Nineteenth Amendment to the United States Constitution. This was a landmark case, prior to this, private citizens were permitted to litigate public rights. | 9–0 |
| Frothingham v. Mellon | 1923 | Held that the generalized injury of higher taxation overall was insufficient to give a taxpayer standing to challenge federal spending. Considered the genesis of the doctrine of standing.[2] | 9–0 |
| Poe v. Ullman | 1961 | Found a lack of standing to challenge a law banning contraceptives as it had never been enforced, and that the controversy was not yet ripe. The same law was successfully challenged four years later in Griswold v. Connecticut. | 5–4 |
| Baker v. Carr | 1962 | Held that voters have standing to litigate when their Constitutional Right to vote in the United States is infringed. | 7–2 |
| Epperson v. Arkansas | 1968 | In contrast to Poe, the court did recognize standing in a case for overturning an unenforced Arkansas state law prohibiting the teaching of evolution.[3] | 9–0 |
| Flast v. Cohen | 1968 | Clarified that Frothingham did not deny all taxpayer lawsuits, identified the Flast test, which gives standing to taxpayers challenging laws are based on the Congressional power to tax and spend, and if the challenged law can be shown to exceed any Constitutional limitations on that power.[4] | 8–1 |
| Sierra Club v. Morton | 1972 | Held that an environmental group, as a corporate entity, did not by itself have standing to challenge a development permit, but that such a group could sue on behalf of any of its members if those members had, themselves, a particularized interest.[5] | 4–3 |
| United States v. SCRAP | 1973 | Held that SCRAP, despite alleging quite attenuated injuries to the local environment due to a proposed rail freight increase on recyclable materials, did assert a particularized harm by showing that its members made use of those areas, and thus enjoyed standing to sue under the principles enunciated in Sierra Club.[6] | 8–0 |
| DeFunis v. Odegaard | 1974 | Held that a student, who had challenged a school's racially discriminatory admissions standards, but who had been allowed to attend college while the case proceeded, lacked standing due to mootness. | 5–4 |
| Valley Forge Christian College v. Americans United for Separation of Church and State | 1982 | Denied standing to Americans United on the grounds that the conditional gift of surplus federal property to a religious college was the result of an Executive Branch action under Article IV rather than a Congressional action taken under the Tax and Spending Clause, and therefore was not covered under the Flast test.[7] | 5–4 |
| Havens Realty Corp. v. Coleman | 1983 | Held that an organization may sue in its own right if it has been directly injured, for example through a "drain on the organization's resources", and that so-called "testers", individuals who sought to determine if a company was in violation of the law, may have standing in their own right.[8] | 9–0[9] |
| City of Los Angeles v. Lyons | 1983 | Held that a plaintiff had standing to sue for damages from being subjected to a chokehold that was allowed under Los Angeles Police Department policy, but did not have standing to sue for an injunction against the chokehold policy itself because the plaintiff could not show a "real and immediate threat" that he would be subjected to the same policy in the future.[10] The Court clarified that courts must find standing for different forms of relief individually.[11] | 5–4 |
| Allen v. Wright | 1984 | Held that a group of African-American parent plaintiffs lacked standing to challenge what they saw as a lack of enforcement of restrictions by the Internal Revenue Service on certain private school tax exemptions, as the plaintiff parents' children had never applied, and had no plans to apply to those schools. | 5–3 |
| County of Riverside v. McLaughlin | 1991 | ||
| Lujan v. Defenders of Wildlife | 1992 | Held that some environmental organizations lacked standing under the Endangered Species Act, and that such a plaintiff must have suffered a tangible, particular harm. | 7–2 |
| Northeastern Fla. Chapter, Associated Gen. Contractors of America v. Jacksonville | 1993 | ||
| Raines v. Byrd | 1997 | Individual Congressmembers lack the particularized interest required for standing for issues affecting the entire Congress, in this case the Line Item Veto Act of 1996. | 7–2 |
| DaimlerChrysler Corp. v. Cuno | 2006 | Held that state taxpayers do not have standing to challenge to state tax laws in federal court. | 9–0 |
| Massachusetts v. EPA | 2007 | States have standing to sue the EPA to enforce their views of federal law, in this case, the view that carbon dioxide was an air pollutant under the Clean Air Act. Cited Georgia v. Tennessee Copper Co. as precedent. | 5–4 |
| Hein v. Freedom From Religion Foundation | 2007 | ||
| Bond v. United States | 2011 | Held that plaintiff had standing to argue that a federal law enforcing the Chemical Weapons Convention in this instance intruded on state police powers. (On the merits, Bond's claim was later rejected.) | 9–0 |
| Hollingsworth v. Perry | 2013 | Held that proponents of a California ballot initiative against gay marriage did not have standing to defend the law in court after the governor and attorney general refused to do so; The decision had the effect of legalizing gay marriage in California | 5–4 |
| Spokeo, Inc. v. Robins | 2016 | Held that there was a distinction between the "concrete" and "particularized" requirements for the "injury in fact" element of the standing test, but remanded without deciding the standing question.[12] | 6–2 |
| Thole v. US Bank | 2020 | Statutory 'cause of action to sue' does not satisfy Article III standing requirements; plaintiffs must have suffered concrete and particularized injury. | 5–4 |
| Carney v. Adams | 2020 | In a case challenging the legality of a law limiting who can apply for judicial vacancies, a plaintiff did not have Article III standing because he failed to show that he was "able and ready" to apply for a judicial vacancy and thus did not suffer personal, concrete, and imminent injury. | 8–0 |
| Uzuegbunam v. Preczewski | 2021 | Nominal damages satisfy Article III's requirement of redressability | 8–1 |
| California v. Texas | 2021 | States and individuals have no Article III standing to block a federal individual mandate of $0 because there is no penalty | 7–2 |
| TransUnion LLC v. Ramirez | 2021 | Only plaintiffs concretely harmed by a defendant's statutory violation have Article III standing to seek damages against that private defendant in federal court | 5–4 |
References edit
- ^ DeLeo, Jr, John D (March 8, 2008). Administrative Law. Cengage Learning. pp. 449–. ISBN 9781401858773. Retrieved February 2, 2013.
- ^ Winter, Steven L. (1988). "The Metaphor of Standing and the Problem of Self-Governance". Stanford Law Review. 40 (6): 1371–1516. doi:10.2307/1228780. JSTOR 1228780.
- ^ Emanuel, Steven; Emanuel, Lazar (October 14, 2008). Constitutional Law. Aspen Publishers Online. pp. 724–. ISBN 9780735570498. Retrieved February 2, 2013.
- ^ Shultz, David (January 1, 2005). The Encyclopedia of the Supreme Court. Infobase Publishing. pp. 167–. ISBN 9780816067398. Retrieved February 2, 2013.
- ^ Yost, Nicholas C.; Institute, Environmental Law (March 1, 2003). Nepa Deskbook. Environmental Law Institute. pp. 22–. ISBN 9781585760565. Retrieved February 2, 2013.
- ^ "United States v. SCRAP, 412 U.S. 669 (1973)". Justia Law. Retrieved November 5, 2023.
- ^ "Valley Forge Coll. v. Americans United, 454 U.S. 464, 485 (1982)". Justia Law. Retrieved November 5, 2023.
- ^ Summary from the National Association of Realtors
- ^ "Havens Realty Corporation v. Coleman". Oyez. Retrieved March 5, 2017.
- ^ "City of Los Angeles v. Lyons, 461 U.S. 95, 105 (1983)". Justia Law. Retrieved November 5, 2023.
- ^ "City of Los Angeles v. Lyons, 461 U.S. 95, 111–13 (1983)". Justia Law. Retrieved November 5, 2023.
- ^ "Spokeo, Inc. v. Robins, 578 U.S. 330, 334 (2016)". Justia Law. Retrieved November 5, 2023.