Allen v. Wright
Encyclopedia
Allen v. Wright, 468 U.S. 737 (1984), was a United States Supreme Court
case that determined that citizens do not have standing
to sue a federal government agency
based on the influence that the agency's determinations might have on third parties.
denies tax-exempt status under the Internal Revenue Code to racially discriminatory private schools, and has established guidelines and procedures for determining whether a particular school is in fact racially nondiscriminatory. As a consequence, those private schools deemed by the IRS to be racially discriminatory are not eligible to receive tax deductible charitable contributions.
Plaintiff
s/respondents, parents of African-American
children in seven states where public schools had recently been desegregated, brought a nation-wide class action lawsuit against the Internal Revenue Service in federal district court, contending that IRS guidelines and procedures for determining whether private schools were racially discriminatory, and subsequent denial of tax exempt status to such schools, were insufficient. Federal law prohibited tax-exempt status to private schools that discriminate on the basis of race, but the parents contended that the standards the IRS used to determine if a school was discriminating were not capable of identifying all of the discriminating private schools. White parents were therefore able to avoid integration by sending their children to the private schools and deducting charitable contributions to the institution, thereby making it harder for black children to attend integrated schools.
Respondents also alleged that many racially segregated private schools (segregation academies) were created or expanded in respondents' communities at the time the public schools were undergoing desegregation, and had received tax exemption
s despite the IRS policy and guidelines; and that these unlawful tax exemptions harmed respondents in that they constituted tangible financial aid for racially segregated educational institutions, and encouraged the organization and expansion of institutions that provided segregated educational opportunities for white students avoiding attendance in the public schools. Respondents did not allege that their children had ever applied or would ever apply for admission to any private school. Respondents sought declaratory and injunctive relief. The District Court dismissed the complaint on the ground that respondents lacked standing to bring the suit and the Court of Appeals reversed. The United States Supreme Court granted cert.
Two injuries were alleged:
to bring the lawsuit.
The court found that the asserted right to hold the government to the law is not enough by itself to create standing to sue. Nor is discrimination enough unless the plaintiff is personally denied equal treatment by the government.
Here, the link between IRS standards and school discrimination was too tenuous. The Court concluded that the doctrine of the separation of powers
dictated this result, because otherwise the courts could always be called upon to restructure the Executive branch.
wrote a dissenting opinion
complaining that the use of separation of powers is a truism. He opined that the injury of the children's opportunities was enough to grant standing to sue.
Justice Stevens wrote that the allegation really is that the government is subsidizing white flight
, which is sufficient to allow standing – the harm (lack of desegregated schools) was traceable to government conduct. Stevens also asserted that standing has nothing to do with separation of powers.
Supreme Court of the United States
The Supreme Court of the United States is the highest court in the United States. It has ultimate appellate jurisdiction over all state and federal courts, and original jurisdiction over a small range of cases...
case that determined that citizens do not have standing
Standing (law)
In law, standing or locus standi is the term for the ability of a party to demonstrate to the court sufficient connection to and harm from the law or action challenged to support that party's participation in the case...
to sue a federal government agency
Government agency
A government or state agency is a permanent or semi-permanent organization in the machinery of government that is responsible for the oversight and administration of specific functions, such as an intelligence agency. There is a notable variety of agency types...
based on the influence that the agency's determinations might have on third parties.
Facts
The Internal Revenue ServiceInternal Revenue Service
The Internal Revenue Service is the revenue service of the United States federal government. The agency is a bureau of the Department of the Treasury, and is under the immediate direction of the Commissioner of Internal Revenue...
denies tax-exempt status under the Internal Revenue Code to racially discriminatory private schools, and has established guidelines and procedures for determining whether a particular school is in fact racially nondiscriminatory. As a consequence, those private schools deemed by the IRS to be racially discriminatory are not eligible to receive tax deductible charitable contributions.
Plaintiff
Plaintiff
A plaintiff , also known as a claimant or complainant, is the term used in some jurisdictions for the party who initiates a lawsuit before a court...
s/respondents, parents of African-American
United States
The United States of America is a federal constitutional republic comprising fifty states and a federal district...
children in seven states where public schools had recently been desegregated, brought a nation-wide class action lawsuit against the Internal Revenue Service in federal district court, contending that IRS guidelines and procedures for determining whether private schools were racially discriminatory, and subsequent denial of tax exempt status to such schools, were insufficient. Federal law prohibited tax-exempt status to private schools that discriminate on the basis of race, but the parents contended that the standards the IRS used to determine if a school was discriminating were not capable of identifying all of the discriminating private schools. White parents were therefore able to avoid integration by sending their children to the private schools and deducting charitable contributions to the institution, thereby making it harder for black children to attend integrated schools.
Respondents also alleged that many racially segregated private schools (segregation academies) were created or expanded in respondents' communities at the time the public schools were undergoing desegregation, and had received tax exemption
Tax exemption
Various tax systems grant a tax exemption to certain organizations, persons, income, property or other items taxable under the system. Tax exemption may also refer to a personal allowance or specific monetary exemption which may be claimed by an individual to reduce taxable income under some...
s despite the IRS policy and guidelines; and that these unlawful tax exemptions harmed respondents in that they constituted tangible financial aid for racially segregated educational institutions, and encouraged the organization and expansion of institutions that provided segregated educational opportunities for white students avoiding attendance in the public schools. Respondents did not allege that their children had ever applied or would ever apply for admission to any private school. Respondents sought declaratory and injunctive relief. The District Court dismissed the complaint on the ground that respondents lacked standing to bring the suit and the Court of Appeals reversed. The United States Supreme Court granted cert.
Two injuries were alleged:
- Direct harm by government financial aid (through allowing tax deductions for donations) to discriminatory schools. This was argued to be a stigmatic injury because of the appearance of government approval for discrimination against blacks.
- Tax exemptions for discriminatory schools impaired the ability of blacks to force desegregation of public schools, because white parents would simply withdraw their children from public schools and place them in discriminatory private schools.
Issue
The Court framed the issue as whether the plaintiffs had standingStanding (law)
In law, standing or locus standi is the term for the ability of a party to demonstrate to the court sufficient connection to and harm from the law or action challenged to support that party's participation in the case...
to bring the lawsuit.
Result
The Court said that the plaintiffs had no standing to bring this suit:- "In essence the question of standing is whether the litigant is entitled to have the court decide the merits of the dispute or of particular issues. Standing doctrine embraces... the general prohibition on a litigant's raising another person's legal rights, the rule barring adjudication of generalized grievances more appropriately addressed in the representative branches, and the requirement that a plaintiff's complaint fall within the zone of interests protected by the law invoked. The requirement of standing, however, has a core component derived directly from the Constitution. A plaintiff must allege personal injury fairly traceable to defendant’s allegedly unlawful conduct and likely to be redressed by the requested relief."
The court found that the asserted right to hold the government to the law is not enough by itself to create standing to sue. Nor is discrimination enough unless the plaintiff is personally denied equal treatment by the government.
Here, the link between IRS standards and school discrimination was too tenuous. The Court concluded that the doctrine of the separation of powers
Separation of powers
The separation of powers, often imprecisely used interchangeably with the trias politica principle, is a model for the governance of a state. The model was first developed in ancient Greece and came into widespread use by the Roman Republic as part of the unmodified Constitution of the Roman Republic...
dictated this result, because otherwise the courts could always be called upon to restructure the Executive branch.
Dissents
Justice BrennanWilliam J. Brennan, Jr.
William Joseph Brennan, Jr. was an American jurist who served as an Associate Justice of the United States Supreme Court from 1956 to 1990...
wrote a dissenting opinion
Dissenting opinion
A dissenting opinion is an opinion in a legal case written by one or more judges expressing disagreement with the majority opinion of the court which gives rise to its judgment....
complaining that the use of separation of powers is a truism. He opined that the injury of the children's opportunities was enough to grant standing to sue.
Justice Stevens wrote that the allegation really is that the government is subsidizing white flight
White flight
White flight has been a term that originated in the United States, starting in the mid-20th century, and applied to the large-scale migration of whites of various European ancestries from racially mixed urban regions to more racially homogeneous suburban or exurban regions. It was first seen as...
, which is sufficient to allow standing – the harm (lack of desegregated schools) was traceable to government conduct. Stevens also asserted that standing has nothing to do with separation of powers.
See also
- Montgomery AcademyMontgomery AcademyThe Montgomery Academy is a non-sectarian independent day school located in Montgomery, Alabama. The school comprises two campuses. The Lower School accommodates kindergarten through fourth grade, and is located at 1550 Perry Hill Road. The Upper School campus, for the fifth through twelfth grades,...
One of the southern private schools named in the lawsuit and ruling. - List of United States Supreme Court cases, volume 468