Warth v. Seldin

Warth v. Seldin, 422 U.S. 490 (1975), was a United States Supreme Court case in which the Court reviewed the concept of judicial standing and affirmed that if the plaintiffs lacked standing, they could not maintain a case against the defendants.

Warth v. Seldin
Argued March 17, 1975
Decided June 25, 1975
Full case nameWarth, et al. v. Seldin, et al.
Citations422 U.S. 490 (more)
95 S. Ct. 2197; 45 L. Ed. 2d 343; 1975 U.S. LEXIS 76
Case history
PriorCert. to the United States Court of Appeals for the Second Circuit
Holding
Petitioners lack standing to sue when not directly injured by the defendant.
Court membership
Chief Justice
Warren E. Burger
Associate Justices
William O. Douglas · William J. Brennan Jr.
Potter Stewart · Byron White
Thurgood Marshall · Harry Blackmun
Lewis F. Powell Jr. · William Rehnquist
Case opinions
MajorityPowell, joined by Burger, Stewart, Blackmun, Rehnquist
DissentDouglas
DissentBrennan, joined by White, Marshall
Laws applied
U.S. Const. Article III

Background

The plaintiffs brought action against the town of Penfield, New York, a suburb of Rochester, and against members of the Zoning, Planning, and Town Boards of Penfield, alleging that Penfield's zoning ordinances intentionally and wrongly excluded persons of low and moderate income from living there.

The not-for-profit housing organization Metro-Act of Rochester joined with several Rochester taxpayers as well as low and moderate-income individuals of various racial and ethnic backgrounds were considered jointly as party-plaintiffs to this action. However, the United States District Court dismissed the case, citing that the plaintiffs did not have standing to sue. The United States Court of Appeals affirmed the dismissal.

The court was tasked to determine if the American rules of standing should be considered part of the 'case or controversy' clause of Article Three of the United States Constitution or, apart from that, if the court can hear cases on "generalized grievances" or in the interest of third parties where none of the complainants have standing.

Opinion of the Court

The Court found that as none of the plaintiffs could demonstrate any injury actually done to them by the defendants, the plaintiffs were third parties to the issue and had no standing to sue. The plaintiff's descriptions of their own meager financial situations and subsequent inability to live in Penfield were found by the Court to be the consequence of the economics and housing market of the area rather than any wrongdoing by the defendants.

  • ^ Text of Warth v. Seldin, 422 U.S. 490 (1975) is available from:  Justia  Library of Congress  Oyez (oral argument audio) 
  • Galloway Jr., Russell W. (1989). "Basic Equal Protection Analysis". Santa Clara Law Review. 29 (1). Retrieved February 8, 2021.
  • Case or Controversy Requirement of Article III
This article is issued from Wikipedia. The text is licensed under Creative Commons - Attribution - Sharealike. Additional terms may apply for the media files.