''Massachusetts v. Mellon'', 262 U.S. 447 (1923), was a
United States Supreme Court
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 ...
case in which the Court rejected the concept of
taxpayer standing
In law, standing or ''locus standi'' is a condition that a party seeking a legal remedy must show they have, by demonstrating to the court, sufficient connection to and harm from the law or action challenged to support that party's participation in ...
. The case was consolidated with ''Frothingham v. Mellon''. The plaintiffs in the cases, Frothingham and Massachusetts, sought to prevent certain federal government expenditures which they considered to violate the
Tenth Amendment
The Tenth Amendment (Amendment X) to the United States Constitution, a part of the Bill of Rights, was ratified on December 15, 1791. It expresses the principle of federalism, also known as states' rights, by stating that the federal governmen ...
. The court rejected the suits on the basis that neither plaintiff suffered particularized harm, writing:
This case is considered the beginning of the doctrine of
standing. Prior to it the doctrine was that all persons had a right to pursue a private prosecution of a
public right.
The
Warren Court would later carve out an exception to this rule in ''
Flast v. Cohen
''Flast v. Cohen'', 392 U.S. 83 (1968), was a United States Supreme Court case holding that a taxpayer has standing to sue the government to prevent an unconstitutional use of taxpayer funds.
The Supreme Court decided in '' Frothingham v. Mellon' ...
'', but later cases have confirmed that ''Flast'' is an exceedingly limited exception to ''Frothingham'' general rule (see ''
Valley Forge Christian College v. Americans United for Separation of Church and State'' and ''
Hein v. Freedom From Religion Foundation'').
References
External links
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United States Constitution Article Three case law
United States Supreme Court cases
1923 in United States case law
United States standing case law
Overruled United States Supreme Court decisions
United States Supreme Court cases of the Taft Court
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