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Arizona Christian School Tuition Organization v. Winn, 563 U.S. 125, 131 S.Ct. 1436, 179 L.Ed.2d 523, 79 USLW 4216, 265 Ed. Law Rep. 855, 11 Cal. Daily Op. Serv. 3982, 2011 Daily Journal D.A.R. 4821, 22 Fla. L. Weekly Fed. S 922

Facts

Arizona's tax code allows taxpayers to receive tax credits for contributions to student tuition organizations (STOs), which provide scholarships for students attending private schools, including religious ones. A group of Arizona taxpayers filed a lawsuit against the director of the State Department of Revenue, arguing that the tax credit violated the Establishment Clause. The District Court dismissed the case, but the Ninth Circuit found that the taxpayers had standing to challenge the law.

Respondents, Arizona taxpayers, sued petitioner director of the State Department of Revenue, challenging Ariz.Rev.Stat. Ann. § 43–1089 on Establishment Clause grounds.

Issue

Did the taxpayers have standing to challenge the Arizona tuition tax credit under the Establishment Clause?

Did the taxpayers have standing to challenge the Arizona tuition tax credit under the Establishment Clause?

Rule

To establish standing in federal court, a plaintiff must demonstrate an 'injury in fact,' a causal connection between the injury and the conduct complained of, and that the injury is likely to be redressed by a favorable decision.

To obtain a ruling on the merits in federal court a plaintiff must assert more than just the “generalized interest of all citizens in constitutional governance.”

Analysis

The Supreme Court determined that the taxpayers did not meet the standing requirements because their challenge was to a tax credit rather than a direct government expenditure. The Court emphasized that taxpayer status alone does not confer standing, and the plaintiffs failed to show a specific injury that was traceable to the tax credit. The Court also noted that the tax credit could potentially relieve the burden on public schools, which further complicated the assertion of injury.

Because respondents challenge a tax credit as opposed to a governmental expenditure, they lack Article III standing under Flast v. Cohen, supra.

Conclusion

The Supreme Court reversed the Ninth Circuit's decision, concluding that the taxpayers lacked standing to challenge the Arizona tuition tax credit.

Held: Because respondents challenge a tax credit as opposed to a governmental expenditure, they lack Article III standing under Flast v. Cohen, supra.

Who won?

Arizona Christian School Tuition Organization prevailed because the Supreme Court found that the taxpayers did not have standing to bring the lawsuit.

The Supreme Court ultimately held that taxpayers lacked standing.

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