Frothingham v. Mellon
Frothingham v. Mellon is a significant Supreme Court case from 1923 that addressed the issue of taxpayer standing in federal court. In this case, Harriet Frothingham, a federal taxpayer, challenged the constitutionality of the Maternity Act of 1921, which allocated federal funds to states for maternal and infant health programs. Frothingham argued that the Act violated the Tenth Amendment and deprived taxpayers of property without due process. The Supreme Court unanimously ruled against her, stating that she lacked standing to sue because she could not demonstrate a specific and direct personal injury resulting from the statute. The ruling highlighted that a general grievance shared by all taxpayers does not suffice for standing in federal court. This case set a precedent regarding taxpayer challenges to federal spending, which would later be revisited in the 1968 case Flast v. Cohen, where the Court established a modified approach to taxpayer standing. This case remains an important reference for understanding the limits of judicial challenges based on taxpayer status.
Frothingham v. Mellon
Date: June 4, 1923
Citation: 262 U.S. 447
Issue: Taxing and spending clause
Significance: The Supreme Court held that payment of taxes does not establish the standing to sue necessary to challenge the constitutionality of congressional spending statutes.
Harriet Frothingham filed suit as a federal taxpayer to prevent the secretary of the treasury from spending money under the Maternity Act of 1921, which provided grants to the states for programs designed to reduce maternal and infant mortality. She alleged that the statute violated the Tenth Amendment and that it also deprived taxpayers of property without due process of law.
By a 9-0 vote, the Supreme Court ruled that the suit was not a legitimate judicial controversy because Frothingham lacked standing to sue. Justice George Sutherland reasoned that the plaintiff in the case would have to show an immediate and direct personal injury from the enforcement of the statute and not merely a remote and uncertain interest shared with all taxpayers. Sutherland wrote that a taxpayer of a municipality would have the necessary standing to sue, but he did not mention possible taxpayer challenges to spending by the states. The Court substantially modified the rule against federal taxpayer standing in Flast v. Cohen (1968).