Allen v. Wright

Supreme Court of the United States · 1984 · Constitutional Law

468 U.S. 737 (1984)

Updated July 29, 2026

Constitutional LawStandingArticle IIISeparation of Powersinjury in factfairly traceableredressabilitystigmatic injury

Facts

Respondents were parents of black children attending public schools in districts undergoing desegregation. They alleged that the IRS had not adopted sufficient standards and procedures to deny tax-exempt status to racially discriminatory private schools, and that some such schools in desegregating districts were unlawfully receiving tax exemptions. Respondents did not allege that their children had applied to, attended, or been excluded from those private schools. They sought prospective declaratory and injunctive relief requiring the IRS to deny exemptions to a broader class of private schools and to replace its existing guidelines.

Issue

Do parents of black public school children have Article III standing to sue the IRS for allegedly failing to deny tax-exempt status to racially discriminatory private schools, based on alleged stigmatic injury from government support of discrimination and alleged impairment of their children's ability to receive a desegregated public education?

Rule

To establish Article III standing, a plaintiff must allege a personal injury that is fairly traceable to the defendant's allegedly unlawful conduct and likely to be redressed by the requested relief. An abstract right to have the government act in accordance with law is insufficient, and stigmatic injury from racial discrimination is cognizable only for persons personally denied equal treatment. Where the asserted injury depends on the independent actions of third parties not before the court, an attenuated causal chain defeats standing.

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One of 10 multiple-choice questions for this case. Pick an answer to see why.

In Phoenix, Maya Carter belongs to a civic association that monitors federal compliance with anti-discrimination law. The association sues the Department of Education, alleging that the agency knowingly continues grants to segregated after-school programs and asking the court to order stricter nationwide screening rules, but Maya alleges no personal denial of any service or opportunity.

Does Maya have Article III standing based on these allegations?

Explanation. Standing requires a personal injury fairly traceable to the challenged conduct and likely redressable by relief. A bare interest in having the government act lawfully is a generalized grievance, not a cognizable Article III injury. Under the majority opinion, federal courts cannot be used simply to supervise executive compliance with law absent a personal injury.