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Warth v. Seldin

Supreme Court of the United States

Argued March 17, 1975 ; June 25, 1975

No. 73-2024

Case Summary

Procedural Posture

Petitioners sought review of a decision from the United States Court of Appeals for the Second Circuit, which held that none of the petitioners had standing to prosecute an action claiming that respondents excluded low income persons from living in respondent town in contravention of various constitutional and statutory rights.

Overview

Petitioners, various organizations and individuals, brought an action against respondent town, and against members of respondent town's planning and zoning boards. Petitioners claimed that respondents' zoning ordinances effectively excluded persons of low and moderate income from living in the town, in contravention of petitioners' constitutional rights and in violation of 42 U.S.C.S. §§ 1981, 1982, and 1983. The lower court held that none of the petitioners had standing to prosecute the action. The court affirmed, holding that the facts alleged failed to support an actionable causal relationship between respondents' zoning practices and petitioners' asserted injury. In contrast to cases where plaintiffs challenged zoning restrictions applied to particular projects that would supply housing within their means, and of which they were intended residents, in this case petitioners were unable to demonstrate that unless relief from the allegedly illegal actions was forthcoming, their immediate and personal interests would be harmed. Thus, the court held that petitioners failed to meet threshold standing requirements and affirmed the judgment below.

Outcome

The judgment below was affirmed based on the court's holding that petitioners failed to meet threshold standing requirements.

LexisNexis® Headnotes

 

 

Civil Procedure > ... > Justiciability > Standing > Personal Stake

Constitutional Law > ... > Case or Controversy > Standing > General Overview

Civil Procedure > Preliminary Considerations > Justiciability > General Overview

Civil Procedure > ... > Justiciability > Standing > General Overview

Constitutional Law > The Judiciary > General Overview

HN1  Standing, Personal Stake

As an aspect of justiciability, the standing question is whether the plaintiff has alleged such a personal stake in the outcome of the controversy as to warrant his invocation of federal-court jurisdiction and to justify exercise of the court's remedial powers on his behalf. The U.S. Const. art. III judicial power exists only to redress or otherwise to protect against injury to the complaining party, even though the court's judgment may benefit others collaterally. A federal court's jurisdiction therefore can be invoked only when the plaintiff himself has suffered some threatened or actual injury resulting from the putatively illegal action.

 

Civil Procedure > ... > Justiciability > Standing > General Overview

Constitutional Law > ... > Case or Controversy > Standing > General Overview

Governments > Federal Government > US Congress

Civil Procedure > Preliminary Considerations > Justiciability > General Overview

HN2  Justiciability, Standing

Congress may grant an express right of action to persons who otherwise would be barred by prudential standing rules. Of course, U.S. Const. art. III's requirement remains: the plaintiff still must allege a distinct and palpable injury to himself, even if it is an injury shared by a large class of other possible litigants. But so long as this requirement is satisfied, persons to whom Congress has granted a right of action, either expressly or by clear implication, may have standing to seek relief on the basis of the legal rights and interests of others, and, indeed, may invoke the general public interest in support of their claim.

 

Civil Procedure > ... > Pleadings > Amendment of Pleadings > General Overview

Constitutional Law > ... > Case or Controversy > Standing > General Overview

Civil Procedure > ... > Justiciability > Standing > General Overview

Civil Procedure > ... > Responses > Defenses, Demurrers & Objections > Motions to Dismiss

HN3  Pleadings, Amendment of Pleadings

For purposes of 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. At the same time, 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. If, after this opportunity, the plaintiff's standing does not adequately appear from all materials of record, the complaint must be dismissed.

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422 U.S. 490 ; 95 S. Ct. 2197 ; 45 L. Ed. 2d 343 ; 1975 U.S. LEXIS 76 

WARTH ET AL. v. SELDIN ET AL.

Prior History:  [1]  CERTIORARI TO THE UNITED STATES COURT OF APPEALS FOR THE SECOND CIRCUIT