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.
Respondents challenged the IRS guidelines and procedures with respect to granting tax-exempt status to private schools under Rev. Proc. 75-50, 1975-2 C.B. 587. Respondents alleged that the IRS violated their rights by granting tax-exempt status to discriminatory private schools. The district court dismissed the action for lack of standing. The court of appeals reversed, holding that respondents had standing and enjoined the IRS from granting tax-exempt status to any racially discriminatory schools.
Did respondents have standing to bring suit?
The first basis for standing alleged by respondents, that they were harmed directly by the mere fact of government financial aid to discriminatory private schools, did not constitute a judicially cognizable injury and their 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 respondents challenged as unlawful.