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Law School Case Brief

Allen v. Wright - 468 U.S. 737, 104 S. Ct. 3315 (1984)


The U.S. Const. art. III doctrine that requires a litigant to have standing to invoke the power of a federal court is perhaps the most important of the case-or-controversy doctrines. In essence the question of standing is whether the litigant is entitled to have the court decide the merits of the dispute or of particular issues. Standing doctrine embraces several judicially self-imposed limits on the exercise of federal jurisdiction, such as the general prohibition on a litigant's raising another person's legal rights, the rule barring adjudication of generalized grievances more appropriately addressed in the representative branches, and the requirement that a plaintiff's complaint fall within the zone of interests protected by the law invoked. The requirement of standing, however, has a core component derived directly from the Constitution. A plaintiff must allege personal injury fairly traceable to the defendant's allegedly unlawful conduct and likely to be redressed by the requested relief. 


Parents of black public school children brought a nationwide class action suit against the U.S. Secretary of the Treasury and the Commissioner of Internal Revenue, alleging that the Internal Revenue Service (IRS) had not adopted sufficient standards and procedures to fulfill its obligation to deny tax-exempt status to racially discriminatory private schools. The United States District Court for the District of Columbia granted defendants' motion to dismiss the complaint, holding that the parents lacked standing. The United States Court of Appeals for the District of Columbia Circuit reversed, holding that the parents had standing to maintain the lawsuit. The United States Supreme Court granted certiorari.


Did the parents have standing?




The Court reversed the court of appeals' ruling and vacated the injunction. The first basis for standing alleged by the parnts, that they were harmed directly by the mere fact of government financial aid to discriminatory private schools, did not constitute a judicially cognizable injury. As to the second basis, that their children were being deprived of an opportunity to receive an education in racially integrated schools, although a judicially cognizable injury, was not fairly traceable to the government conduct that the parents challenged as unlawful.

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