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 |
FDA v. Alliance for Hippocratic Medicine | 2024 | A plaintiff's desire to make a drug less available for others does not create Article III standing | 9–0 |
Murthy v. Missouri | 2024 | States and individual social-media users have no Article III standing to enjoin Government agencies and officials from pressuring or encouraging social-media platforms to suppress protected speech in the future. | 6-3 |
The First Amendment to the United States Constitution prevents the government from making laws respecting an establishment of religion; prohibiting the free exercise of religion; or abridging the freedom of speech, the freedom of the press, the freedom of assembly, or the right to petition the government for redress of grievances. It was adopted on December 15, 1791, as one of the ten amendments that constitute the Bill of Rights.
The Fourteenth Amendment to the United States Constitution was adopted on July 9, 1868, as one of the Reconstruction Amendments. Usually considered one of the most consequential amendments, it addresses citizenship rights and equal protection under the law and was proposed in response to issues related to formerly enslaved Americans following the American Civil War. The amendment was bitterly contested, particularly by the states of the defeated Confederacy, which were forced to ratify it in order to regain representation in Congress. The amendment, particularly its first section, is one of the most litigated parts of the Constitution, forming the basis for landmark Supreme Court decisions such as Brown v. Board of Education (1954) regarding racial segregation, Loving v. Virginia (1967) regarding interracial marriage, Roe v. Wade (1973) regarding abortion, Bush v. Gore (2000) regarding the 2000 presidential election, Obergefell v. Hodges (2015) regarding same-sex marriage, and Students for Fair Admissions v. Harvard (2023) regarding race-based college admissions. The amendment limits the actions of all state and local officials, and also those acting on behalf of such officials.
The Supreme Court of the United States (SCOTUS) is the highest court in the federal judiciary of the United States. It has ultimate appellate jurisdiction over all U.S. federal court cases, and over state court cases that turn on questions of U.S. constitutional or federal law. It also has original jurisdiction over a narrow range of cases, specifically "all Cases affecting Ambassadors, other public Ministers and Consuls, and those in which a State shall be Party." The court holds the power of judicial review: the ability to invalidate a statute for violating a provision of the Constitution. It is also able to strike down presidential directives for violating either the Constitution or statutory law.
John Paul Stevens was an American lawyer and jurist who served as an associate justice of the Supreme Court of the United States from 1975 to 2010. At the time of his retirement, he was the second-oldest justice in the history of the U.S. Supreme Court and the third-longest-serving justice. At the time of his death in 2019 at age 99, he was the longest-lived Supreme Court justice ever. His long tenure saw him write for the Court on most issues of American law, including civil liberties, the death penalty, government action, and intellectual property. Despite being a registered Republican who throughout his life identified as a conservative, Stevens was considered to have been on the liberal side of the Court at the time of his retirement.
The Comstock Actof 1873 refers to a series of current provisions in Federal law that generally criminalize the involvement of the United States Postal Service, its officers, or a common carrier in conveying obscene matter, crime-inciting matter, or certain abortion-related matter. The Comstock Act is largely codified across title 18 of the United States Code and was enacted beginning in 1872 with the attachment of an extraneous rider to a postal service reconsolidation bill. Amended multiple times since initial enactment, with most recently in 1996, the Act is nonetheless often associated with U.S. Postal Inspector and anti-vice activist Anthony Comstock.
McConnell v. Federal Election Commission, 540 U.S. 93 (2003), is a case in which the United States Supreme Court upheld the constitutionality of most of the Bipartisan Campaign Reform Act (BCRA), often referred to as the McCain–Feingold Act.
Friends of the Earth, Inc. v. Laidlaw Environmental Services, Inc., 528 U.S. 167 (2000), was a United States Supreme Court case that addressed the law regarding standing to sue and mootness.
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Lujan v. Defenders of Wildlife, 504 U.S. 555 (1992), was a landmark Supreme Court of the United States decision, handed down on June 12, 1992, that heightened standing requirements under Article III of the United States Constitution. It is "one of the most influential cases in modern environmental standing jurisprudence." Lily Henning of the Legal Times stated that:
United States v. Virginia, 518 U.S. 515 (1996), is a landmark case in which the Supreme Court of the United States struck down the long-standing male-only admission policy of the Virginia Military Institute (VMI) in a 7–1 decision. Justice Clarence Thomas, whose son was enrolled at the university at the time, recused himself.
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Rapanos v. United States, 547 U.S. 715 (2006), was a United States Supreme Court case challenging federal jurisdiction to regulate isolated wetlands under the Clean Water Act. It was the first major environmental case heard by the newly appointed Chief Justice, John Roberts, and Associate Justice Samuel Alito. The Supreme Court heard the case on February 21, 2006, and issued a decision on June 19, 2006.
United States v. Students Challenging Regulatory Agency Procedures (SCRAP), 412 U.S. 669 (1973), was a landmark decision of the United States Supreme Court in which the Court held that the members of SCRAP—five law students from the George Washington University Law School—had standing to sue under Article III of the Constitution to challenge a nationwide railroad freight rate increase approved by the Interstate Commerce Commission (ICC). SCRAP was the first full-court consideration of the National Environmental Policy Act (NEPA). The Court also reversed the lower court decision that an injunction should be issued at the suspension stage of the ICC rate proceeding. The standing decision has retained its place as the high mark in the Court's standing jurisprudence.
William Hubbs Rehnquist was an American attorney and jurist who served as the 16th chief justice of the United States from 1986 until his death in 2005, having previously been an associate justice from 1972 to 1986. Considered a staunch conservative, Rehnquist favored a conception of federalism that emphasized the Tenth Amendment's reservation of powers to the states. Under this view of federalism, the Court, for the first time since the 1930s, struck down an act of Congress as exceeding its power under the Commerce Clause.
City of Los Angeles v. Lyons, 461 U.S. 95 (1983), was a United States Supreme Court decision holding that the plaintiff, Adolph Lyons, lacked standing to challenge the Los Angeles city police department's use of chokeholds.
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American Trucking Ass'ns, Inc. v. City of Los Angeles, 569 U.S. 641 (2013), was a case in which the Supreme Court of the United States held that certain regulations imposed by City of Los Angeles on trucking companies were preempted by federal law. In 2006 the Board of Harbor Commissioners for Los Angeles, California adopted an environmental protection plan that included an effort called Clean Truck Program (CTP). The stated goal of the program is to "reduce negative impacts that port [trucking] inflicts on the local community." The implementation of this program began in 2007 and required trucking companies to comply with various requirements relating to maintenance of trucks, employment of drivers, and trucking operations. The American Trucking Associations believed some of the regulations were in violation of the Federal Aviation Administration Authorization Act of 1994 (FAAAA) and filed suit. Litigation eventually made its way up to the Supreme Court of the United States, where the Court held that two of the requirements of the CTP were in violation of the FAAAA.
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