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Encyclopedia > Allen v. Wright

Allen v. Wright, 468 U.S. 737 (1984) was a United States Supreme Court case that determined that citizens do not have standing to sue a federal government agency based on the influence that the agency's determinations might have on third parties. Court citation is a standard system used in common law countries such as the United States, United Kingdom, and Canada to uniquely identify the location of past court cases in special series of books called reporters. ... 1984 is a leap year starting on Sunday of the Gregorian calendar. ... The Supreme Court Building, Washington, D.C. The Supreme Court Building, Washington, D.C., (large image) The Supreme Court of the United States, located in Washington, D.C., is the highest court (see supreme court) in the United States; that is, it has ultimate judicial authority within the United States... In law, standing is the ability of a party to demonstrate to the court sufficient connection to and harm from the law or action challenged. ...

Contents

Facts

Plaintiffs, African-American parents in seven U.S. states where schools had recently been desegregated, sued the Internal Revenue Service, contending that IRS guidelines for determining whether a private school was racially discriminatory were insufficient. Federal law prohibited taxpayers from deducting the costs of tuition that was paid to private schools that discriminate on the basis of race, but the parents contended that the standards the IRS used to determine if a school was discriminating were not capable of identifying all of the discriminating private schools. White parents were therefore able to avoid integration by sending their children to the private schools and deducting the cost of tuition, thereby making it harder for black children to attend integrated schools. The plaintiff, claimant, or complainant is the party initiating a lawsuit, (also known as an action). ... African Americans, also known as Afro-Americans or Black Americans, are an ethnic group in the United States of America whose ancestors, usually in predominant part, were indigenous to Sub-Saharan Africa. ... A U.S. state is any one of the 50 states which have membership of the federation known as the United States of America (USA or U.S.). The separate state governments and the U.S. federal government share sovereignty. ... This article needs cleanup. ... The Internal Revenue Service (IRS) is the United States government agency that collects taxes and enforces the tax laws. ... A tax deduction or a tax-deductible expense, is an item which is subtracted from gross income in order to arrive at the taxable income. ... Tuition is a fee charged for educational instruction. ...


Two injuries were alleged:

  • 1. Direct harm by government financial aid (through allowing tax deductions for donations) to discriminatory schools. This was argued to be a stigmatic injury because of the appearance of government approval for discrimination against blacks.
  • 2. Tax exemptions for discriminatory schools impaired the ability of blacks to force desegregation of public schools, because white parents would simply withdraw their children from public schools and place them in discriminatory private schools.

Issue

The Court framed the issue as whether the plaintiffs had standing to bring the lawsuit. In law, standing is the ability of a party to demonstrate to the court sufficient connection to and harm from the law or action challenged. ...


Result

The Court said that the plaintiffs had no standing to bring this suit:

"In essence the question of standing is whether the litigant is entitled to have the court decide the merits of the dispute or of particular issues. Standing doctrine embraces... the general prohibition on a litigant's raising another person's legal rights, the rule barring adjudication of generalized grievances more appropriately addressed in the representative branches, and the requirement that a plaintiff's complaint fall within the zone of interests protected by the law invoked. The requirement of standing, however, has a core component derived directly from the Constitution. A plaintiff must allege personal injury fairly traceable to defendant’s allegedly unlawful conduct and likely to be redressed by the requested relief."

The court found that the asserted right to hold the government to the law is not enough by itself to create standing to sue. Nor is discrimination enough unless the plaintiff is personally denied equal treatment by the government. Here, the link between IRS standards and school discrimination was too tenuous. The Court concluded that the doctrine of the separation of powers dictated this result, because otherwise the courts could always be called upon to restructure the Executive branch. Separation of powers is the idea that the powers of a sovereign government should be split between two or more strongly independent entities, preventing any one person or group from gaining too much power. ... Under the doctrine of the separation of powers, the executive is the branch of a government charged with implementing, or executing, the law. ...


Dissents

Justice Brennen wrote a dissenting opinion complaining that the use of separation of powers is a truism. Injury of kids' opportunities was enough. Justice Stevens wrote that the allegation really is that the government is subsidizing white flight, which is good enough – it causes a harm (lack of desegregated schools) traceable to government conduct. He also asserted that standing has nothing to do with separation of powers.



 
 

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