Law School Case Brief
Singleton v. Wulff - 428 U.S. 106, 96 S. Ct. 2868 (1976)
It is the general rule, that a federal appellate court does not consider an issue not passed upon below. It is essential that parties may have the opportunity to offer all the evidence they believe relevant to the issues and in order that litigants may not be surprised on appeal by final decision there of issues upon which they have had no opportunity to introduce evidence.
Respondents, two Missouri-licensed physicians, brought an action for injunctive relief and a declaration of the unconstitutionality of a Missouri statute that excluded abortions that are not "medically indicated" from the purposes for which Medicaid benefits are available to needy persons. In response to Singleton's pre-answer motion to dismiss, each respondent averred that he had provided, and anticipated providing, abortions to needy patients, and that Singleton, the responsible state official, acting in reliance on the challenged statute, had refused all Medicaid applications filed in connection with such abortions. A three-judge District Court dismissed the relevant count of the complaint for lack of standing, having concluded that no logicial nexus existed between the status asserted by respondents and the claim that they sought to have adjudicated. On appeal, the Court of Appeals reversed, finding that respondents had alleged sufficient "injury in fact" and also an interest "arguably within the zone of interests to be protected… by the… constitutional guarantees in question." That court then considered the case on the merits and found that the challenged statute clearly violated the Equal Protection Clause. The Chief of the Bureau of Medical Service of Missouri sought review of the decision. The Supreme Court of the United States granted certiorari.
The first question: Did the physicians have standing? The second question: Whether the federal appellate court properly proceeded to a determination of the merits?
The Court held that the physicians were qualified to litigate the constitutionality of the Chief's interference with, or discrimination against, an abortion funding decision, because there were significant obstacles that could have prevented women patients from litigating. The Court affirmed the appellate court's decision to allow the physicians to assert the rights of women patients as against the Chief's interference with abortion. Nevertheless, the Court reversed the appellate court's determination of the issue on the merits. The Court held that the appellate court erred by determining the claim on its merits when the Chief had not presented evidence but only filed a motion for dismissal. Injustice was more likely to be caused than avoided by deciding the issue without the Chief's having had an opportunity to be heard.
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