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Warth v. Seldin

Supreme Court of the United States · 1975 · Constitutional Law

Constitutional LawStandingJusticiabilityArticle IIIinjury in factcausationredressabilitygeneralized grievance

Facts

Petitioners alleged that Penfield's zoning ordinance allocated nearly all vacant land to single-family detached housing and imposed requirements that made low- and moderate-cost housing economically infeasible, while town officials allegedly delayed, denied, and obstructed proposals for such housing. Low- and moderate-income minority plaintiffs claimed they had been unable to obtain housing in Penfield and therefore had to live elsewhere in less attractive environments. Rochester taxpayers claimed Penfield's practices increased Rochester's tax burden, and organizational plaintiffs claimed injury to their members, including lost business opportunities and loss of the benefits of living in an integrated community. The complaint sought declaratory and injunctive relief and damages.

Issue

Whether the various individual and organizational petitioners had standing to challenge Penfield's allegedly exclusionary zoning practices. More specifically, the Court considered whether they alleged a personal, concrete injury fairly traceable to respondents' conduct and likely to be redressed by judicial relief, and whether prudential limits barred them from asserting the rights of others.

Rule

A plaintiff invoking federal jurisdiction must allege specific, concrete facts showing a distinct and palpable personal injury caused by the defendant's challenged conduct and likely to be removed by the requested relief. Beyond Article III, federal courts ordinarily will not entertain generalized grievances or claims resting on the legal rights or interests of third parties unless Congress has expressly or by clear implication created such a right of action. An association may seek prospective relief for its members only if its members themselves would have standing, but it may not recover damages for members where the injuries and proof are individualized.

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

Tanya Brooks and Luis Mercado, low-income residents of Cleveland, sue the suburb of Fairview Heights, Ohio, alleging its zoning code makes apartments and small homes too expensive for families like theirs. They say they would like to live there, but they identify no pending housing project, no developer prepared to build affordable units for them, and no facts showing they could obtain housing there if the code were invalidated.

Do Tanya and Luis have the strongest basis for Article III standing?

Explanation. The majority required specific, concrete facts showing personal injury fairly traceable to the challenged zoning and likely to be removed by the requested relief. Where plaintiffs merely assert a desire to live in the municipality, but rely on speculative future actions of third-party developers and do not show that relief would probably make suitable housing available to them, standing is lacking. The case does not hold zoning claims are categorically nonjusticiable.