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''Fairchild v. Hughes'', 258 U.S. 126 (1922), was a case in which the
On July 7, 1920,
In February, the Court announced a unanimous decision authored by Associate Justice
Supreme Court of the United States
The Supreme Court of the United States (SCOTUS) is the highest court in the federal judiciary of the United States. It has ultimate appellate jurisdiction over all U.S. federal court cases, and over state court cases that involve a point o ...
held that a general citizen, in a state that already had women's suffrage
Suffrage, political franchise, or simply franchise, is the right to vote in representative democracy, public, political elections and referendums (although the term is sometimes used for any right to vote). In some languages, and occasionally i ...
, lacked standing to challenge the validity of the ratification of the Nineteenth Amendment.. A companion case, ''Leser v. Garnett
''Leser v. Garnett'', 258 U.S. 130 (1922), was a case in which the Supreme Court of the United States held that the Nineteenth Amendment had been constitutionally established..
Prior history
On August 26, 1920, the ratification of the Ninet ...
'', upheld the ratification.
Background
In 1919, the United States Congress 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 the proposal, with only one additional state needed for the Amendment to be adopted.
On July 7, 1920, Charles S. Fairchild
Charles Stebbins Fairchild (April 30, 1842 – November 24, 1924) was an American businessman and politician who served as United States Secretary of the Treasury from 1887 to 1889 and Attorney General of New York from 1876 to 1877. He was a not ...
challenged the validity of the ratification process for that Amendment in the Supreme Court of the District of Columbia. The challenge sought to prevent Secretary of State Charles Evans Hughes 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'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
Louis Dembitz Brandeis (; November 13, 1856 – October 5, 1941) was an American lawyer and associate justice on the Supreme Court of the United States from 1916 to 1939.
Starting in 1890, he helped develop the "right to privacy" concept ...
, concluding that Fairchild, as a private citizen, lacked standing 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 review: ...
of Article III. On the same day, the Court also decided a companion case, ''Leser v. Garnett
''Leser v. Garnett'', 258 U.S. 130 (1922), was a case in which the Supreme Court of the United States held that the Nineteenth Amendment had been constitutionally established..
Prior history
On August 26, 1920, the ratification of the Ninet ...
'' 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
''Massachusetts v. Mellon'', 262 U.S. 447 (1923), was a United States Supreme Court case in which the Court rejected the concept of taxpayer standing. The case was consolidated with ''Frothingham v. Mellon''. The plaintiffs in the cases, Frothing ...
'', that became the genesis of the doctrine of legal standing. However, the term standing was not associated with Article III until the New Deal
The New Deal was a series of programs, public work projects, financial reforms, and regulations enacted by President Franklin D. Roosevelt in the United States between 1933 and 1939. Major federal programs agencies included the Civilian Cons ...
era.
See also
* List of United States Supreme Court cases, volume 258References
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