Valley Forge Christian Coll. v. Ams. United for Separation of Church & State

454 U.S. 464, 102 S. Ct. 752 (1982)



A litigant must have standing to challenge the action sought to be adjudicated in a lawsuit. At an irreducible minimum, U.S. Const. art. III requires the party who invokes the court's authority to show that he personally has suffered some actual or threatened injury as a result of the putatively illegal conduct of the defendant and that the injury fairly can be traced to the challenged action and is likely to be redressed by a favorable decision.


Respondents, a nonprofit organization and its employees, brought an action to compel petitioner religious institution to transfer property back to the United States on the ground that the conveyance of the property to petitioner under the Federal Property and Administrative Services Act of 1949, 40 U.S.C.S. § 471 et seq., was unconstitutional. The trial court dismissed respondents' action for lack of standing, and on appeal the circuit court reversed, finding that respondents had standing as citizens alleging a violation of their personal rights under the Establishment Clause, U.S. Const. art. I. On further appeal, the Court reversed again, holding that enforcement of the Establishment Clause did not create an exception to the requirement under U.S. Const. art. III that a plaintiff had to allege a distinct and palpable injury to himself in order to invoke judicial power. 


Did the organization and its employees have standing to challenge the conveyance of the surplus property?




The organization and its employees had no standing to challenge the conveyance of the surplus property, since (1) they were without standing to sue as taxpayers, the source of their complaint not being a congressional action and the property transfer about which they complained not being an exercise of authority conferred by the taxing and spending clause of the United States Constitution (Art I, 8), the authorizing legislation rather being an exercise of Congress' power under the property clause (Art IV, 3, cl 2), and (2) the organization and its employees had not sufficiently alleged any other basis for standing to bring the action, they having failed to identify any personal injury suffered by them as a consequence of the alleged constitutional error, other than the psychological consequences presumably produced by observation of conduct with which one disagrees.

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