Venue: |
SCOTUS
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Facts: |
Mrs. Frothingham objects to the Maternity Act of 1921 (providing
funds for the reduction of infant and maternal mortality).
She argues that taxing her to fund this is deprivation of
property without due process of law. |
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Posture: |
Dismissed for "want of jurisdiction," because the plaintiff
has "no such interest in the subject matter, nor is any
such injury inflicted or threatened, as will enable her
to sue." |
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Issue: |
Can a taxpayer who doesn't like legislated policy sue? |
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Holding: |
Not this taxpayer. Only if there's a case that presents a
justiciable issue. |
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Rule: |
A citizen of a municipality can sue regarding the application
of the city's money, but SCOTUS has no power simply to
review annual acts of congress for constitutionality; they
can only hear actual cases and controversies, which means
there has to be a "direct injury suffered or threatened,"
and a national taxpayer's interests are indirect and
diluted. |
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Reasoning: |
An individual's interest in the national treasury is minute
and diluted. So remote, so fluctuating, so uncertain, that
no basis is afforeded to appeal to a court of equity. |
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Dicta: |
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