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''Fairchild v. Hughes'', 258 U.S. 126 (1922), was a case in which the Supreme Court of the United States held that a general citizen, in a state that already had women's suffrage, lacked
On July 7, 1920, Charles S. Fairchild challenged the validity of the ratification process for that Amendment in the
In February, the Court announced a unanimous decision authored by Associate Justice Louis Brandeis, concluding that Fairchild, as a private citizen, lacked
standing
Standing, also referred to as orthostasis, is a position in which the body is held in an ''erect'' ("orthostatic") position and supported only by the feet. Although seemingly static, the body rocks slightly back and forth from the ankle in the s ...
to challenge the validity of the ratification of the Nineteenth Amendment.. A companion case, '' Leser v. Garnett'', upheld the ratification.
Background
In 1919, theUnited States Congress
The United States Congress is the legislature of the federal government of the United States. It is bicameral, composed of a lower body, the House of Representatives, and an upper body, the Senate. It meets in the U.S. Capitol in Washing ...
proposed a Constitutional amendment reading: "Section 1: The right of citizens of the United States to vote shall not be denied or abridged by the United States or by any State on account of sex." "Section 2: Congress shall have power to enforce this article by appropriate legislation." By July 1920, thirty-five states had ratified
Ratification is a principal's approval of an act of its agent that lacked the authority to bind the principal legally. Ratification defines the international act in which a state indicates its consent to be bound to a treaty if the parties inten ...
the proposal, with only one additional state needed for the Amendment to be adopted.
On July 7, 1920, Charles S. Fairchild challenged the validity of the ratification process for that Amendment in the Supreme Court of the District of Columbia
The United States District Court for the District of Columbia (in case citations, D.D.C.) is a federal district court in the District of Columbia. It also occasionally handles (jointly with the United States District Court for the District of ...
. The challenge sought to prevent Secretary of State Charles Evans Hughes
Charles Evans Hughes Sr. (April 11, 1862 – August 27, 1948) was an American statesman, politician and jurist who served as the 11th Chief Justice of the United States from 1930 to 1941. A member of the Republican Party, he previously was the ...
from officially declaring the Amendment valid. The district court dismissed the case on July 20, and Fairchild appealed to the Court of Appeals of the District of Columbia. On August 26, Hughes acknowledged Tennessee
Tennessee ( , ), officially the State of Tennessee, is a landlocked state in the Southeastern region of the United States. Tennessee is the 36th-largest by area and the 15th-most populous of the 50 states. It is bordered by Kentucky to th ...
's ratification, and the Nineteenth Amendment to the United States Constitution became law. The Court of Appeals affirmed the lower court decision. The case was appealed to the Supreme Court. In November 1921, the Supreme Court agreed to hear the case, which was argued in January 1922.
Opinion of the Court
In February, the Court announced a unanimous decision authored by Associate Justice Louis Brandeis, concluding that Fairchild, as a private citizen, lacked standing
Standing, also referred to as orthostasis, is a position in which the body is held in an ''erect'' ("orthostatic") position and supported only by the feet. Although seemingly static, the body rocks slightly back and forth from the ankle in the s ...
to challenge the amendment's ratification under the limitations of the Case or Controversy Clause
The Supreme Court of the United States has interpreted the Case or Controversy Clause of Article III of the United States Constitution (found in Art. III, Section 2, Clause 1) as embodying two distinct limitations on exercise of judicial revie ...
of Article III. On the same day, the Court also decided a companion case, '' Leser v. Garnett'' which upheld the Amendment's ratification process on the merits.
The ''Fairchild'' decision marked a departure from prior doctrine, which had allowed any citizen to sue to preserve a public right.The Metaphor of Standing and the Problem of Self-Governance, by Steven L. Winter, 40 ''Stan. L. Rev.'' 1371, July, 1988.
Subsequent developments
This case is often seen as one of two cases, along with '' Frothingham v. Mellon'', that became the genesis of thedoctrine
Doctrine (from la, doctrina, meaning "teaching, instruction") is a codification of beliefs or a body of teachings or instructions, taught principles or positions, as the essence of teachings in a given branch of knowledge or in a belief syste ...
of legal standing. However, the term standing was not associated with Article III until the New Deal era.
See also
*List of United States Supreme Court cases, volume 258
This is a list of cases reported in volume 258 of ''United States Reports'', decided by the Supreme Court of the United States in 1922.
Justices of the Supreme Court at the time of volume 258 U.S.
The Supreme Court is established by Ar ...
References
External links
* {{USArticleIII 1922 in United States case law United States gender discrimination case law United States Supreme Court cases United States Supreme Court cases of the Taft Court United States Nineteenth Amendment case law United States Constitution Article Three case law