Allen v. Wright

Infobox SCOTUS case
Litigants=Allen v. Wright
ArgueDate=February 29
ArgueYear=1984
DecideDate=July 3
DecideYear=1984
FullName=Allen v. Wright, "et al."
USVol=468
USPage=737
Citation=104 S. Ct. 3315; 82 L. Ed. 2d 556; 1984 U.S. LEXIS 149; 52 U.S.L.W. 5110; 84-2 U.S. Tax Cas. (CCH) P9611; 54 A.F.T.R.2d (RIA) 5361
Prior=Certiorari to the United States Court of Appeals for the District of Columbia Circuit
Subsequent=
Holding=Parties lack standing to sue where the policies of a government agency are alleged to be insufficient to prevent school segregation.
SCOTUS=1981-1986
Majority=O'Connor
JoinMajority=Burger, White, Powell, Rehnquist
Dissent=Brennan
Dissent2=Stevens
JoinDissent2=Blackmun
NotParticipating=Marshall
LawsApplied=U.S. Const. art. III

"Allen v. Wright", 468 U.S. 737 (1984)ref|citation, 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.

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 tax-exempt status 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 charitable contributions to the institution, thereby making it harder for black children to attend integrated schools.

Two injuries were alleged:
# 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.
# 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.

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.

Dissents

Justice Brennan wrote a dissenting opinion complaining that the use of separation of powers is a truism. He opined that the injury of the children's opportunities was enough to grant standing to sue.

Justice Stevens wrote that the allegation really is that the government is subsidizing white flight, which is sufficient to allow standing – the harm (lack of desegregated schools) was traceable to government conduct. Stevens also asserted that standing has nothing to do with separation of powers.

See also

*Montgomery Academy One of the southern private schools named in the lawsuit and ruling.
* List of United States Supreme Court cases, volume 468

External links

*ussc|468|737|Text of the opinion on Findlaw.com