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Allen v. Wright, 468 U.S. 737 (1984)

SUBJECT:

standing

FACTS:

Parents of black children attending public schools in districts undergoing desegregation brought nationwide class action alleging that Internal Revenue Service had not adopted sufficient standards and procedures to fulfill its obligation to deny tax-exempt status to racially discriminatory private schools. Alleged (1) that they were, as blacks, stigmatized by the granting of tax exemptions to racially discriminatory schools, (2) the denial of their rights to have their children attend a desegregated private schools, the IRS made the task of desegregating the public schools more difficult.

Procedure:

The United States District Court for the District of Columbia, George L. Hart, Jr., J., dismissed on standing grounds. The Court of Appeals for the District of Columbia, reversed and remanded. Certiorari was granted.

ISSUE:

Whether petitioners have standing.

RULE:

 

 

HOLDING:

Respondents do not have standing to bring this suit

The Supreme Court, Justice O'Connor, held that: (1) parents did not have standing to prevent the government from violating the law in granting tax exemptions; (2) absent allegation of direct injury, standing could not be predicated on claim of stigmatization caused by racial discrimination; and (3) claim of injury to their children's diminished ability to receive an education in a racially integrated school, although a judicially cognizable injury, failed because the alleged injury was not fairly traceable to the government's conduct that was challenged as unlawful.

RATIONALE:

  1. doctrine of "standing" has a core constitutional component that a plaintiff must allege personal injury fairly traceable to the defendant's allegedly unlawful conduct and likely to be redressed by the requested relief.
  2. Nor do respondents have standing to litigate their claim based on the stigmatizing injury often caused by racial discrimination. Such injury accords a basis for standing only to those persons who are personally denied equal treatment by the challenged discriminatory conduct, and respondents do not allege a stigmatic injury suffered as a direct result of having personally been denied equal treatment.
  3. To recognize respondents' standing to seek a restructuring of the apparatus established by the Executive Branch to fulfill its legal duties would run afoul of the idea of separation of powers that underlies standing doctrine.

POLICY/NOTES: