Keywords: abortion, Medicaid, case or controversy, Equal Protection Clause, medicine, United States Supreme Court, standing, third party beneficiary, Article III, law, case briefs
Summary of Singleton v. Wulff, 428 U.S. 106, 96 S. Ct. 2868, 49 L. Ed. 2d. 826 (1976).
Missouri passed a law that denied Medicaid benefits to needy persons for abortions that were not “medically indicated”. Wulff and another Missouri physician (P) brought suit in federal district court seeking an injunction against enforcement of the law and a declaratory judgment that the law was unconstitutional. Each plaintiff averred that he had provided and would continue to provide abortions to needy patients and that Singleton (D) as the responsible state official had refused all applications for Medicaid benefits.
The district court granted the defendant’s motion to dismiss, holding that the plaintiffs did not have standing to bring suit because there was no logical nexus between the plaintiffs’ status and the cause of action. The court of appeals reversed, holding that the plaintiffs had alleged sufficient injury in fact to support the claim, and that the plaintiffs had an interest of the sort that was protected by the constitutional guarantees in question. The court held that the plaintiffs had standing based on the constitutional right of a doctor to practice medicine, and based on the third party rights of their patients.
The court of appeals then considered the case on the merits and ruled that the statute was unconstitutional for violating the Equal Protection Clause. The Supreme Court granted certiorari.
Under what circumstances may a party obtain standing to assert third party rights?
Holding and Rule (Blackmun)
A party may obtain standing to adjudicate third-party rights if there are obstacles to the assertion by the third party of her own rights, and the existence of some relationship such as the one between physician and patient.
This case presents two distinct issues of standing: 1) whether the plaintiffs allege injury in fact, i.e. a sufficiently concrete interest in the outcome of the suit to make it a case or controversy subject to a federal court’s jurisdiction under Article III; and 2) whether the plaintiffs are proper proponents of the particular legal rights on which they base their suit.
Courts must hesitate before resolving a controversy based on the rights of third persons not parties to the litigation for two reasons. 1) The holders of those rights may not wish to assert them, or may be able to enjoy them regardless of whether the third party claimant is successful. 2) Third parties themselves usually will be the best proponents of their own rights. The courts depend on effective advocacy and therefore should prefer to construe legal rights only when the most effective advocates of those rights are before them. These two considerations underlie the Court’s general rule that ordinarily one may not claim standing to vindicate the constitutional rights of some third party.
The Court has looked primarily to two factual elements to determine whether the rule should apply in a particular case: 1) the relationship of the litigant to the person whose right he seeks to assert; and 2) the ability of the third party to assert his own right.
While we agree with the court of appeals that the plaintiffs have standing, it was incorrect for that court to decide the case on the merits.
Reversed and remanded.
The plaintiffs clearly have standing because they have a financial stake in the outcome of the litigation, and they claim that the statute impairs their own constitutional rights.
Concurring in Part and Dissenting in Part (Powell)
I agree that the plaintiffs have standing to assert their own constitutional rights, and that the court of appeals erred in deciding the case on the merits. I dissent however from the holding by the plurality that the plaintiffs may assert the constitutional rights of their patients.
See Epperson v. Arkansas for a constitutional law case brief in which the dissent stated that the case did not present a case or controversy because the statute at issue had never been and would probably never be enforced.
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