Allen v. Wright, 468 U.S. 737 (1984)

DECISION: Parents of black public school children held not to have standing to challenge grant of tax exemptions to racially discriminatory private schools.

SUMMARY: Parents of black public school children brought a nationwide class action suit against the Secretary of the Treasury and the Commissioner of Internal Revenue, alleging that the Internal Revenue Service (IRS) had not adopted sufficient standards and procedures to fulfill its obligation to deny tax-exempt status to racially discriminatory private schools. The United States District Court for the District of Columbia granted the defendants' motion to dismiss the complaint, holding that the parents lacked standing. The United States Court of Appeals for the District of Columbia Circuit reversed, holding that the parents had standing to maintain the lawsuit (656 F2d 820).

On certiorari, the United States Supreme Court reversed. In an opinion by O'Connor, J., joined by Burger, Ch. J., and White, Powell, and Rehnquist, JJ., it was held that parents of black public school children did not have standing under Article III of the United States Constitution to bring a suit alleging that the IRS has not adopted sufficient standards and procedures to fulfill its obligation to deny tax-exempt status to racially discriminatory private schools. The court said that the parents' allegation that they were harmed directly by the mere fact of government financial aid to discriminatory private schools cannot support standing because it did not constitute a judicially cognizable injury. The court further said that the parents' allegation that federal tax exemptions to racially discriminatory private schools in their communities impair their ability to have their public schools desegregated cannot also support standing because the alleged injury was not fairly traceable to the assertedly unlawful conduct of the IRS.

Brennan, J., dissented, expressing the view that the plaintiffs alleged a direct causal relationship between the government action they challenge and the injury they suffer in that their children's inability to receive an education in a racially integrated school is directly and adversely affected by the tax exempt-status granted by the IRS to racially discriminatory schools in their respective school districts.

Stevens, J., joined by Blackmun, J., dissented, expressing the view that (1) the plaintiffs adequately alleged injury in fact; (2) their injury is fairly traceable to the conduct that they claim to be unlawful; and (3) the separation of powers principle does not create a jurisdictional obstacle to the consideration of the merits of their claim.

Marshall, J., did not participate.