Warth v. Seldin
Encyclopedia
Warth v. Seldin, 422 U. S. 490
(1975), was a United States Supreme Court case in which the Court reviewed the concept of judicial standing and affirmed that if the plaintiffs lacked standing
, they could not maintain a case against the defendants.
, a suburb of Rochester
, and against members of the Zoning, Planning, and Town Boards of Penfield, alleging that Penfield's zoning ordinances intentionally and wrongly excluded persons of low and moderate income from living there.
The not-for-profit housing organization Metro-Act of Rochester joined with several Rochester taxpayers as well as low and moderate income individuals of various racial and ethnic backgrounds were considered jointly as party-plaintiffs to this action. However, the United States District Court
dismissed the case, citing that the plaintiffs did not have standing to sue. The United States Court of Appeals
confirmed the dismissal.
rules of standing should be considered part of the 'case or controversy' clause of Article Three of the United States Constitution
or, apart from that, if the court can hear cases on "generalized grievances" or in the interest of third parties where none of the complaintants have standing.
Case citation
Case citation is the system used in many countries to identify the decisions in past court cases, either in special series of books called reporters or law reports, or in a 'neutral' form which will identify a decision wherever it was reported...
(1975), was a United States Supreme Court case in which the Court reviewed the concept of judicial standing and affirmed that if the plaintiffs lacked standing
Standing (law)
In law, standing or locus standi is the term for the ability of a party to demonstrate to the court sufficient connection to and harm from the law or action challenged to support that party's participation in the case...
, they could not maintain a case against the defendants.
Facts
The plaintiffs brought action against the town of Penfield, New YorkPenfield, New York
Penfield is a town in Monroe County, New York, United States. The population was 36,242 at the 2010 census.The town was incorporated in 1810 by the proprietor, Daniel Penfield, who purchased the town lands in 1795 and moved to the area in 1809. Penfield is a suburb of Rochester, New York...
, a suburb of Rochester
Rochester, New York
Rochester is a city in Monroe County, New York, south of Lake Ontario in the United States. Known as The World's Image Centre, it was also once known as The Flour City, and more recently as The Flower City...
, and against members of the Zoning, Planning, and Town Boards of Penfield, alleging that Penfield's zoning ordinances intentionally and wrongly excluded persons of low and moderate income from living there.
The not-for-profit housing organization Metro-Act of Rochester joined with several Rochester taxpayers as well as low and moderate income individuals of various racial and ethnic backgrounds were considered jointly as party-plaintiffs to this action. However, the United States District Court
United States district court
The United States district courts are the general trial courts of the United States federal court system. Both civil and criminal cases are filed in the district court, which is a court of law, equity, and admiralty. There is a United States bankruptcy court associated with each United States...
dismissed the case, citing that the plaintiffs did not have standing to sue. The United States Court of Appeals
United States court of appeals
The United States courts of appeals are the intermediate appellate courts of the United States federal court system...
confirmed the dismissal.
Issue
The court was tasked to determine if the AmericanUnited States
The United States of America is a federal constitutional republic comprising fifty states and a federal district...
rules of standing should be considered part of the 'case or controversy' clause of Article Three of the United States Constitution
Article Three of the United States Constitution
Article Three of the United States Constitution establishes the judicial branch of the federal government. The judicial branch comprises the Supreme Court of the United States and lower courts as created by Congress.-Section 1: Federal courts:...
or, apart from that, if the court can hear cases on "generalized grievances" or in the interest of third parties where none of the complaintants have standing.
Result
The court found that as none of the plaintiffs could demonstrate any injury actually done to them by the defendants, the plaintiffs were third parties to the issue and had no standing to sue. The plaintiff's descriptions of their own meager financial situations and subsequent inability to live in Penfield were found by the Court to be the consequence of the economics and housing market of the area rather than any wrong doing by the defendants.See also
- List of United States Supreme Court cases, volume 422
- List of United States Supreme Court cases, volume 423
- List of United States Supreme Court cases, volume 424