Tileston v. Ullman

Supreme Court of the United States · Federal Courts

Federal CourtsStandingFourteenth Amendmentstandingthird-party standingFourteenth Amendmentdeclaratory judgmentconstitutional question

Facts

The appellant, a registered physician, alleged that Connecticut statutes prohibiting the use of drugs or instruments to prevent conception, and giving assistance or counsel in their use, would prevent him from giving professional advice about contraceptives to three patients. He alleged that those patients' health conditions were such that child-bearing would endanger their lives, and that state law enforcement officers intended to prosecute offenses under the statutes and claimed or might claim that his proposed advice would violate them. The complaint described in detail the danger to the patients' lives if they bore children. But the complaint did not allege that the statutes infringed the physician's own liberty or property rights under the Fourteenth Amendment.

Issue

Whether the physician had standing to challenge the statutes under the Fourteenth Amendment based on the claim that their enforcement would endanger the lives of his patients. More specifically, the question was whether he could assert his patients' constitutional right to life when they were not parties and had not asserted that right themselves.

Rule

A party may not obtain adjudication of a constitutional claim based solely on the alleged deprivation of the rights of third parties who are not before the court and do not assert those rights on their own behalf. Where the record raises no constitutional claim involving the appellant's own liberty, property, or life, the appellant lacks standing to press the constitutional issue.

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

Dr. Nina Patel, a licensed physician in Columbus, Ohio, seeks a declaratory judgment against state health officials. She alleges that a state statute barring advice about a certain medical procedure will put two of her patients at grave medical risk if they cannot receive her counseling, but her complaint says nothing about any deprivation of her own life, liberty, or property.

Should a court dismiss the constitutional claim for lack of standing?

Explanation. The majority rule is that a litigant may not obtain adjudication of a constitutional claim based solely on alleged deprivation of rights belonging to third parties who are not before the court and do not assert those rights on their own behalf. Here, the complaint alleges only injury to the patients, not to Dr. Patel's own life, liberty, or property. That is the same standing defect requiring dismissal. (Derived from Tileston v. Ullman (n.d.).)