Simon v. E. Ky. Welfare Rights Org.

426 U.S. 26, 96 S. Ct. 1917 (1976)

 

RULE:

When a plaintiff's standing is brought into issue, the relevant inquiry is whether, assuming justiciability of the claim, the plaintiff has shown an injury to himself that is likely to be redressed by a favorable decision.

FACTS:

Plaintiff indigents and indigent groups brought an action under 5 U.S.C.S. § 702, alleging that the Internal Revenue Service violated the Internal Revenue Code and the Administrative Procedure Act by issuing a revenue ruling allowing favorable tax treatment to nonprofit hospitals that only offered emergency-room services to indigents instead of full hospital services. The complaint alleged specific occasions on which each of the individual plaintiffs was denied medical treatment. Plaintiffs failed to name any of the hospitals as defendants in the complaint. Defendants, the Secretary of the Treasury and the Commissioner of Internal Revenue, filed a motion to dismiss challenging plaintiffs' standing. The trial court overruled the motion and declared the revenue ruling as void. The appellate court also found that plaintiffs had standing and upheld the revenue ruling. On plaintiffs’ appeal, the Supreme Court of the United States vacated the appellate court’s decision.

ISSUE:

Did plaintiff indigents and indigent groups have standing to sue defendants, the Secretary of the Treasury and the Commissioner of Internal Revenue, for the adoption of a revenue ruling which allegedly "encouraged" hospitals to deny services to indigents, without establishing actual injury to any of their indigent members?

ANSWER:

No.

CONCLUSION:

Plaintiff indigents and indigent groups lacked standing to bring the suit since they failed to establish that the asserted injury was the consequence of defendants' actions. It was purely speculative whether the denials of service specified in the complaint fairly could be traced to defendants' "encouragement" or instead resulted from decisions made by the hospitals without regard to the tax implications. Further, there was no substantial likelihood that victory in the suit would result in plaintiffs receiving the hospital treatment they desired.

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