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Keywords

lawsuitplaintiffdefendantappealrespondent
lawsuitplaintiffdefendantprecedentappealclass actionrespondentwrit of certiorari

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Allen v. Wright, 468 U.S. 737, 104 S.Ct. 3315, 82 L.Ed.2d 556, 54 A.F.T.R.2d 84-5361, 84-2 USTC P 9611, 18 Ed. Law Rep. 82, 1984-2 C.B. 106

Facts

The respondents, parents of black children in public schools undergoing desegregation, alleged that the IRS had not implemented adequate standards to deny tax-exempt status to racially discriminatory private schools. They claimed that these tax exemptions provided financial support to segregated schools, thereby harming their children's educational opportunities in integrated public schools. The parents sought declaratory and injunctive relief but did not claim that their children had ever applied to or would apply to any private school.

Respondents, parents of black children who were attending public schools in seven States in school districts undergoing desegregation, brought a nationwide class action in Federal District Court against petitioner Government officials… Respondents do not allege that their children had ever applied or would ever apply for admission to any private school.

Issue

Did the parents of black children have standing to sue the IRS for allegedly failing to deny tax-exempt status to racially discriminatory private schools?

The issue before us is whether plaintiffs have standing to bring this suit. We hold that they do not.

Rule

To establish standing, a plaintiff must demonstrate a personal injury that is fairly traceable to the defendant's conduct and likely to be redressed by the requested relief.

A plaintiff must allege personal injury fairly traceable to the defendant's allegedly unlawful conduct and likely to be redressed by the requested relief.

Analysis

The Supreme Court analyzed the standing requirements under Article III of the Constitution, concluding that the parents' claims did not meet the necessary criteria. The Court found that the alleged injuries, including stigmatization and diminished educational opportunities, were not directly traceable to the IRS's actions regarding tax exemptions. The Court emphasized that standing cannot be based on abstract injuries or generalized grievances.

The first fails under clear precedents of this Court because it does not constitute judicially cognizable injury. The second fails because the alleged injury is not fairly traceable to the assertedly unlawful conduct of the IRS.

Conclusion

The Supreme Court reversed the Court of Appeals' decision, holding that the parents lacked standing to bring the lawsuit against the IRS.

Held: Respondents do not have standing to bring this suit.

Who won?

The Internal Revenue Service (IRS) prevailed in the case because the Supreme Court found that the parents did not have standing to challenge the IRS's tax exemption policies.

The Government defendants and defendant-intervenor Allen filed separate petitions for a writ of certiorari in this Court. They both sought review of the Court of Appeals' holding that respondents have standing to bring this lawsuit.

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