The Wright family, along with other parents of black public school children, brought a
class action suit against the Secretary of the Treasury and the Commissioner of Internal
Revenue at the IRS.
Allen, the head of a private school identified in the complaint, intervened as a defendant.
The parents argued that the failure of the IRS to deny tax-exempt status to racially
segregated private schools caused injury to their children on two grounds.
First, the parents alleged that the IRS’s failure to comply with desegregation laws
caused them direct harm by creating a climate of stigma against their children.
Second, the parents claimed that their children’s ability to attend a desegregated school had
been directly impaired, because the IRS’s failure to remove private schools’ tax-exempt
status effectively encouraged the existence of segregated schools.
The parents sought declaratory and injunctive relief in federal district court.
The district court dismissed the complaint on the ground that the parents lacked standing
to bring the suit.
The court of appeals reversed, and the United States Supreme Court granted certiorari.
The issue on appeal was whether the parents had standing, that is, whether they needed
to show that they had personally suffered a distinct injury and establish a chain of
causation linking that injury to actions taken by the defendants.
The Supreme Court found that such a demonstration was necessary for the plaintiffs to have standing.
Justice O’Connor, writing for the majority, explained it was not sufficient for the plaintiffs
to simply allege that the government had acted outside of the requirements of the law.
Rather, they must be able to show direct injury by the defendants in order to have standing.
As a result, the Wright family lacked standing to sue on the first ground of their complaint,
because they did not allege a sufficiently personal injury.
Additionally, the Court found that the parents lacked standing to sue on the second ground,
because the chain of causation linking the alleged inability of their children to attend
a desegregated school to the specific actions of the IRS was too far removed.
In other words, the plaintiffs’ injury was not fairly traceable to the IRS’s conduct.
There was no evidence that if the IRS actually withheld tax-exempt status from the private
schools that the segregation policies would change.
Furthermore, the majority claimed that it was necessary to refuse standing to the parents
in order to uphold separation of powers.
The Court is required, under Article III of the United States Constitution, to adjudicate
only actual “cases and controversies.”
Hearing this case would require the Court to overstep its constitutionally prescribed
bounds and interfere with the Executive Branch’s duty to faithfully execute the laws.
Therefore, the Court reversed the court of appeals’ judgment granting standing to the
parents.
Justice Brennan and Justice Stevens dissented.
Brennan asserted that the parents’ allegation that children were being denied the opportunity
to attend desegregated schools was enough to grant standing.
Meanwhile, Stevens reasoned that the IRS’s actions would subsidize “white flight”
to private schools with segregating policies.
Therefore, he found that the alleged injury in this case was sufficiently personal to
justify standing, and that the parents alleged sufficient causation between the actions of
the IRS and the injury suffered by their children.
This case is significant, because it outlines the three requirements for standing in federal
courts under Article III: injury, causation, and redressability.
There remains some debate amongst scholars over whether the requirements for constitutional
standing laid out in this case are necessary to give effect to the case-or-controversy
requirement.
Some argue that the prerequisites are unduly burdensome and keep meritorious claims out
of federal courts.
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