Warth v. Seldin

422 U.S. 490, 95 S. Ct. 2197 (1975)



As an aspect of justiciability, the standing question is whether the plaintiff has alleged such a personal stake in the outcome of the controversy as to warrant his invocation of federal-court jurisdiction and to justify exercise of the court's remedial powers on his behalf. The U.S. Const. art. III judicial power exists only to redress or otherwise to protect against injury to the complaining party, even though the court's judgment may benefit others collaterally. A federal court's jurisdiction therefore can be invoked only when the plaintiff himself has suffered some threatened or actual injury resulting from the putatively illegal action.


Petitioners, various organizations and individuals, brought an action against respondent town, and against members of respondent town's planning and zoning boards. Petitioners claimed that respondents' zoning ordinances effectively excluded persons of low and moderate income from living in the town, in contravention of petitioners' constitutional rights and in violation of 42 U.S.C.S. §§ 19811982, and 1983. The lower court held that none of the petitioners had standing to prosecute the action.


Did the petitioners have standing to bring an action against members of respondent town's planning and zoning boards?




The court affirmed, holding that the facts alleged failed to support an actionable causal relationship between respondents' zoning practices and petitioners' asserted injury. In contrast to cases where plaintiffs challenged zoning restrictions applied to particular projects that would supply housing within their means, and of which they were intended residents, in this case petitioners were unable to demonstrate that unless relief from the allegedly illegal actions was forthcoming, their immediate and personal interests would be harmed. Thus, the court held that petitioners failed to meet threshold standing requirements and affirmed the judgment below.

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