Fairchild v. Hughes

Supreme Court of the United States · 1922 · Federal Courts

Federal CourtsstandingArticle IIIcase or controversygeneralized grievancecitizen suitconstitutional amendmentinjunction

Facts

Fairchild, a New York citizen, taxpayer, and member of the American Constitutional League, filed an equity suit against the Secretary of State and the Attorney General challenging the impending proclamation and enforcement of the Nineteenth Amendment. He alleged that the amendment could not validly become part of the Constitution through ratification by state legislatures and that several state ratifications were inoperative. He further alleged that the Secretary intended to proclaim adoption upon receiving one more certificate and that a proposed federal "force bill" would be enforced by the Attorney General if enacted. Fairchild claimed the proclamation would mislead election officers, cause women to vote in states limiting suffrage to men, void elections, diminish the effectiveness of lawful votes, and increase election expenses.

Issue

Whether a private citizen, taxpayer, and association member with only a general interest in lawful government administration has a sufficient Article III interest to maintain a federal suit seeking to have the Nineteenth Amendment declared void and to enjoin executive officials from proclaiming or enforcing it.

Rule

A federal court lacks Article III jurisdiction when the plaintiff asserts only the general right possessed by every citizen to require that government be administered according to law and public moneys not be wasted. Such a generalized interest does not permit a private citizen to bring a federal suit to obtain, indirectly, a determination whether a contemplated statute or constitutional amendment will be valid.

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

In Columbus, Ohio, Aaron Pike files suit in federal court against the Secretary of the Treasury seeking to block certification of a newly proposed constitutional amendment concerning federal fiscal rules. Aaron alleges only that unlawful certification would mislead state officials, distort public administration, and waste tax dollars nationwide.

Should the federal court dismiss for lack of Article III standing?

Explanation. Yes. The controlling rule is that a private citizen cannot invoke federal judicial power based only on the general right shared by all citizens to have government administered according to law and public money not wasted. A suit that is essentially an attempt to obtain a ruling on the validity of an anticipated governmental act, without a personal right being protected or a personal legal wrong being redressed, is not a "case" within Article III.