Use this button to switch between dark and light mode.

Share your feedback on this Case Brief

Thank You For Submiting Feedback!

  • Law School Case Brief

Blumenthal v. Trump - 445 U.S. App. D.C. 169, 949 F.3d 14 (2020)

Rule:

No principle is more fundamental to the judiciary's proper role in the court's system of government than the constitutional limitation of federal-court jurisdiction to actual cases or controversies. Standing to sue is a doctrine rooted in the traditional understanding of a case or controversy. To establish Article III standing, a plaintiff must, as an irreducible constitutional minimum, (1) suffer an injury in fact, (2) that is fairly traceable to the challenged conduct of the defendant, and (3) that is likely to be redressed by a favorable judicial decision. Put differently, the court's standing inquiry precedes the court's merits analysis and focuses on whether the plaintiff is the proper party to bring the suit.

Facts:

215 Members of the Congress (Members) sued President Donald J. Trump based on allegations that he has repeatedly violated the United States Constitution's Foreign Emoluments Clause. The President moved to dismiss, arguing that the Members lacked standing, and that they failed to state a claim upon which relief could be granted. The district court denied the President’s motion to dismiss, holding that the Members had an implied equitable cause of action for injunctive relief and that they had stated a claim under the Clause.

Issue:

Did the district court err in denying the President’s motion to dismiss the claim? 

Answer:

Yes.

Conclusion:

The Court reversed the district court’s decision, holding that the Members of Congress lacked standing to bring an emoluments clause action against the President under U.S. Const. art. I, § 9, cl. 8 because individual members of the Congress lack standing to assert the institutional interests of the legislature. According to the Court, only an institution can assert an institutional injury provided the injury was not wholly abstract and widely dispersed. The Court further held that the district court erred in holding that the Members suffered an injury based on the President depriving them of the opportunity to give or withhold their consent to foreign emoluments.

Access the full text case

Essential Class Preparation Skills

  • How to Answer Your Professor's Questions
  • How to Brief a Case
  • Don't Miss Important Points of Law with BARBRI Outlines (Login Required)

Essential Class Resources

  • CivPro
  • Contracts
  • Constitutional Law
  • Corporations /Business Organizations
  • Criminal Law
  • Criminal Procedure/Investigation
  • Evidence
  • Legal Ethics/Professional Responsibility
  • Property
  • Secured Transactions
  • Torts
  • Trusts & Estates