The Oyez Project: Judicial Power Issues - Personal Injury Decisions

Allen v. Wright

Did the IRS shirk its enforcement duties and encourage private schools to racially discriminate, thus, harming desegregation efforts in the nation's public schools?

The Court found that the circumstances involved in this case did not warrant federal-court adjudication. Justice O'Connor's opinion argued that the Court could not act since the injuries that the suit identified were not "judicially cognizable" and because they were not "fairly traceable to the assertedly unlawful conduct of the IRS." Citing past precedents, O'Connor found that, by itself, an assertion that the government is not acting in the bounds of the law is not enough to bring a suit to a federal court. To allow so would open the door to a myriad of legal challenges in which the courts would become buried by the minutiae of governing, acting as "continuing monitors of the wisdom and soundness of Executive action."

Automobile Workers v. Brock

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Barlow v. Collins

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Craig v. Boren

Did an Oklahoma statute violate the Fourteenth Amendment's Equal Protection Clause by establishing different drinking ages for men and women?

In a 7-to-2 decision, the Court held that the statute made unconstitutional gender classifications. The Court held that the statistics relied on by the state of Oklahoma were insufficient to show a substantial relationship between the law and the maintenance of traffic safety. Generalities about the drinking habits of aggregate groups did not suffice. The Court also found that the Twenty-first Amendment did not alter the application of the Equal Protection Clause in the case.

Data Processing Service v. Camp

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Diamond v. Charles

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Eisenstadt v. Baird

Did the Massachusetts law violate the right to privacy acknowledged in Griswold v. Connecticut and protected from state instrusion by the Fourteenth Amendment?

In a 6-to-1 decision, the Court struck down the Massachusetts law but not on privacy grounds. The Court held that the law's distinction between single and married individuals failed to satisfy the "rational basis test" of the Fourteenth Amendment's Equal Protection Clause. Married couples were entitled to contraception under the Court's Griswold decision. Withholding that right to single persons without a rational basis proved the fatal flaw. Thus, the Court did not have to rely on Griswold to invalidate the Massachusetts statute. "If the right of privacy means anything, wrote Justice William J. Brennan, Jr. for the majority, "it is the right of the individual, married or single, to be free from unwarranted governmental intrusion tino matters so fundamentally affecting a person as the decision to whether to bear or beget a child."

Elk Grove Unified School District v. Newdow

Does Michael Newdow have standing to challenge as unconstitutional a public school district policy that requires teachers to lead willing students in reciting the Pledge of Allegiance? Does a public school district policy that requires teachers to lead willing students in reciting the Pledge of Allegiance, which includes the words "under God," violate the Establishment Clause of the First Amendment?

In an opinion authored by Justice John Paul Stevens, the Supreme Court found that Newdow did not have standing to bring suit because he did not have sufficient custody over his daugther. "When hard questions of domestic relations are sure to affect the outcome, the prudent course is for the federal court to stay its hand rather than reach out to resolve a weighty question of federal constitutional law," Justice Stevens wrote. Because it found that Newdow did not have standing, the Court failed to reach the constitutional question. Chief Justice Renquist and Justices Sandra Day O'Connor and Clarence Thomas all wrote seperate concurrences, saying that requiring teachers to lead the Pledge is constitutional.

Griswold v. Connecticut

Does the Constitution protect the right of marital privacy against state restrictions on a couple's ability to be counseled in the use of contraceptives?

Though the Constitution does not explicitly protect a general right to privacy, the various guarantees within the Bill of Rights create penumbras, or zones, that establish a right to privacy. Together, the First, Third, Fourth, and Ninth Amendments, create a new constitutional right, the right to privacy in marital relations. The Connecticut statute conflicts with the exercise of this right and is therefore null and void.

Investment Co. Institute v. Camp

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Karcher v. May

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Kowalski v. Tesmer

(1) Does the 14th Amendment guarantee an indigent criminal defendant convicted by a guilty plea the right to an appointed appellate attorney in a discretionary first appeal? (2) Do attorneys have third-party standing on behalf of potential indigent defendants to make a constitutional challenge to a state statute prohibiting appointment of appellate counsel in discretionary first appeals following convictions by guilty pleas?

In a 6-3 opinion delivered by Chief Justice William H. Rehnquist, the Court held that the attorneys lacked third-party standing to sue on behalf of the Michigan indigent defendants. The attorneys did not have close relationships with the indigent defendants, nor was there a hindrance to these defendants' ability to advance their own constitutional rights against the Michigan scheme. In addition, under Younger, the indigents should have only turned to the federal courts after pursuing their claims in state court.

Los Angeles v. Lyons

Did Lyons's injunction against the use of police chokeholds meet the threshold requirements imposed by Article III of the Constitution?

No. In a 5-to-4 decision, the Court held that federal courts were without jurisdiction to entertain Lyons' claim for injunctive relief. The fact that Lyons had been choked once did nothing to establish "a real and immediate threat that he would again be stopped. . .by an officer who would illegally choke him into unconsciousness." The Court held that in order to establish an actual controversy, Lyons would have to show either 1) that all Los Angeles police officers always choked citizens with whom they had encounters, or 2) that the City ordered or authorized officers to act in such a manner. Lyons was thus limited to suing the police and the city for individual damages.

Lujan v. National Wildlife Federation

Does an organization representing private citizens who use public land "in the vicinity" of areas affected by Bureau of Land Management (BLM) land-use designations have standing to challenge those designations under section 10(e) of the Administrative Procedure Act? Does standing to challenge several individual BLM decision confer standing to challenge those decisions as a whole, even when the organization's members are not affected by the bulk of the decisions?

No and no. In a 5-to-4 decision written by Justice Antonin Scalia, the Supreme Court held that NWF did not have standing to challenge the land-use designations. The two timely affidavits were not enough to show that the group members had actually been affected by the BLM decisions. Even if they had been, and if the four additional affidavits had been considered (which the Supreme Court ruled had not been necessary), the right to challenge the individual decisions would not have conveyed a right to challenge all of them. The decisions were not a single "agency action" but rather a series of actions which would have to be challenged individually. "The case-by-case approach that this requires is understandably frustrating to an organization such as [NWF], which has as its objective across-the-board protection of our Nation's wildlife and the streams and forests that support it," wrote Justice Scalia. "But this is the traditional, and remains the normal, mode of operation of the courts. ... Until confided to us, ... more sweeping actions are for the other branches."

Moose Lodge No. 107 v. Irvis

Did the discriminatory practices violate the Equal Protection Clause of the Fourteenth Amendment?

No. In a 6-to-3 decision, the Court held that the Moose Lodge's refusal to serve food and beverages to Irvis because he was black did not violate the Fourteenth Amendment. The Court noted that the state action doctrine did not necessarily apply to all private entities that received benefits or services from the government; otherwise, the Court reasoned, all private associations that received electricity, water, and fire protection would be subject to state regulation. The Court found that the Moose Lodge "a private social club in a private building," and thus not subject to the Equal Protection Clause.

NAACP v. Alabama

Did Alabama's requirement violate the Due Process Clause of the Fourteenth Amendment?

Yes. The unanimous Court held that a compelled disclosure of the NAACP's membership lists would have the effect of suppressing legal association among the group's members. Nothing short of an "overriding valid interest of the State," something not present in this case, was needed to justify Alabama's actions.

O'shea v. Littleton

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Railroad Trans. Service v. Chicago

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Raines v. Byrd

Did the congressmen have Article III standing to challenge the Line Item Veto Act as a violation of the Presentment Clause in Article I?

No. In a 7-to-2 decision, which avoided the question of the Act's constitutionality, the Court held that the individual congressmen lacked proper Article III standing to maintain their suit. The Court explained that the congressmen failed to show how the allegedly unconstitutional Act resulted in their personal injury, since it applied to the entire institution of Congress. Moreover, the congressmen based their claim on a loss of political power rather then a demonstration of how the Act violated one of their particularized legally protected interests. The Court concluded that, having failed to meet both of these standing requirements, the congressmen did not present the Court with a case-or-controversy over which it had jurisdiction.

Singleton v. Wulff

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Sinkfield v. Kelley

Do white Alabama voters, who are residents of various majority-white districts, have standing to challenge Alabama's re-districting plan, which had an acknowledged purpose of maximizing the number of majority-minority districts?

No. In a unanimous per curiam opinion, the Court held that the appellees lacked standing to maintain their challenge. The opinion stated that the appellees "have neither alleged nor produced any evidence that any of them was assigned to his or her district as a direct result of having 'personally been subjected to a racial classification.'" Consequently, the appellees lacked standing.

United States v. Hays

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Whitmore v. Arkansas

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Wyoming v. Oklahoma

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