Allen v. Wright – Case Brief Summary
Summary of Allen v. Wright, 468 U.S. 737, 104 S. Ct. 3315, 82 L. Ed. 2d 556 (1984).
The Internal Revenue Service denied tax-exempt status to racially discriminatory private schools and established guidelines for determining whether particular schools were racially nondiscriminatory. Wright and other parents (P) of black children who were attending public schools undergoing desegregation brought a nationwide class action lawsuit against the IRS and certain private schools in federal district court, seeking declaratory and injunctive relief. Allen (D) was the head of one of the private school systems named as a defendant.
Wright alleged that the IRS had not adopted standards and procedures sufficient to satisfy its obligation to deny tax-exempt status to racially discriminatory private schools, thereby harming the plaintiffs directly and interfering with their children’s opportunity to attend desegregated public schools. Wright also alleged that many racially segregated private schools had been created or expanded while the public schools were undergoing desegregation, and that these private schools had received tax exemptions despite the IRS policy. There was no allegation that the children of the plaintiffs had ever or would ever apply for admission to any private school.
The District Court permitted intervention as a defendant by petitioner Allen. The District Court dismissed the complaint for lack of standing. The Court of Appeals reversed and the Supreme Court granted cert.
What is required in order for a party to have standing to bring suit?
Holding and Rule
The Article III doctrine of “standing” requires 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.
Federal courts may exercise power only in the last resort and as a necessity, and only when adjudication is consistent with a system of separated powers and the dispute is one traditionally thought to be capable of resolution through the judicial process.
The plaintiffs’ claim that they are harmed directly by the mere fact of Government financial aid to discriminatory private schools fails because it does not constitute judicially cognizable injury. An asserted right to have the Government act in accordance with law, without more, is not sufficient to confer jurisdiction on a federal court.
Plaintiffs also do not have standing 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.
The plaintiffs’ claim of injury arising from their children’s diminished ability to receive an education in a racially integrated school – though a judicially cognizable injury – fails because the alleged injury is not fairly traceable to the Government conduct that is challenged as unlawful. Respondents have not alleged that there were enough racially discriminatory private schools receiving tax exemptions in respondents’ communities for withdrawal of those exemptions to make an appreciable difference in public school integration.
It is entirely speculative whether withdrawal of a particular school’s tax exemption would have a significant impact on the racial composition of the public schools. To recognize respondents’ standing to seek a restructuring of the apparatus established by the Executive Branch to fulfill its legal duties would be contrary to the idea of separation of powers that underlies standing doctrine. The Constitution assigns to the Executive Branch, not to the Judicial Branch, the duty to take care that the laws be faithfully executed.
Reversed (for defendant Allen).
See DeFunis v. Odegaard for a constitutional law case brief involving an issue of mootness. Plaintiff DeFunis claimed that his rejection by the University of Washington law school, which had admitted allegedly less qualified minority applicants through affirmative action, amounted to race based discrimination.