Constitutional Law I, Pages 74–76

Valley Forge Christian College v. Americans United for Separation of Church and State

1982

Facts:

A federal statute which allowed the government to dispose of surplus property by conveying it to nonprofit tax-exempt educational institutions at a reduced price for public benefit. Based on this, the Department of Health, Education, and Welfare gave a surplus military hospital building to a Christian college for the public benefit. Plaintiffs sued, claiming that this constituted the government establishing religion in violation of the First Amendment and that they had standing because it affected them as citizens and as taxpayers.

Issue:

Do plaintiffs have standing?

Rule:

Google Scholar LogoPage 75

Art. III requires the party who invokes the court's authority to "show that he personally has suffered some actual or threatened injury as a result of the putatively illegal conduct of the defendant," and that the injury "fairly can be traced to the challenged action" and "is likely to be redressed by a favorable decision,"

Reasoning:

Some "injury in fact" must be shown to have standing in the Supreme Court. Otherwise, cases would have no factual context to base it on, could open the courts to more cases with most of the same facts, and can affect the lives, liberty, and property of everyone else. Judiciary power should be a right of last resort. It is also prudential to require that the injury be to oneself, to refrain from "abstract questions of wide public significance" which amount to "generalized grievances," and to require that the complaint fall in the "zone of interests to be protected or regulated by the statute or constitutional guarantee in question."

Plaintiffs lack standing from their tax burden claim, because their burden was "remote, fluctuating, and uncertain." They lack standing for being a citizen because their interest in how the government functions was insufficiently personal to constitute injury in fact.

Holding:

No, plaintiffs do not have standing as either taxpayers or as citizens.

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