Fairchild V. Hughes
258 U.S. 126, 42 S. Ct. 274 (1922)
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Rule of Law:
A private citizen lacks standing to sue in federal court to challenge the validity of a constitutional amendment or statute based on a generalized grievance that the government is not being administered according to law.
Facts:
- Charles S. Fairchild was a citizen of the United States and New York and a member of the American Constitutional League.
- Fairchild objected to the ratification process of the Nineteenth Amendment, which granted women the right to vote.
- He alleged that the Secretary of State was preparing to proclaim the amendment's adoption upon receiving the required number of state ratifications, which Fairchild believed were invalid.
- Fairchild claimed that the proclamation would mislead election officials, diminish the effectiveness of his vote, create void elections, and nearly double election expenses.
- The State of New York, where Fairchild was a citizen, had already amended its own constitution to grant suffrage to women and had ratified the Nineteenth Amendment.
- Fairchild was not an election official who would be subject to penalties under a proposed federal bill to enforce women's suffrage.
Procedural Posture:
- Charles S. Fairchild brought suit against the Secretary of State and the Attorney General in the Supreme Court of the District of Columbia (a trial court).
- Fairchild sought an injunction to prevent the proclamation and enforcement of the Nineteenth Amendment.
- The defendants moved to dismiss the bill.
- The trial court dismissed the bill.
- Fairchild appealed to the Court of Appeals of the District of Columbia (an intermediate appellate court).
- The Court of Appeals affirmed the trial court's dismissal.
- The case then came to the Supreme Court of the United States for review.
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Issue:
Does a private citizen have standing to sue in federal court to seek an injunction against the proclamation and enforcement of a constitutional amendment by asserting only a general interest in having the government follow the law?
Opinions:
Majority - Mr. Justice Brandeis
No. A private citizen's lawsuit to invalidate a constitutional amendment, based on a general right to have the government administered according to law, does not constitute a 'case' or 'controversy' under Article III of the Constitution. The Court reasoned that Fairchild failed to show he had sustained, or was in immediate danger of sustaining, some direct injury as a result of the amendment's enforcement. His interest in the suit was not a personal, legally protected right, but rather a general interest shared with all members of the public. He was not an election officer threatened with prosecution, and his home state of New York had already granted women the right to vote. Therefore, his suit was not a proper proceeding for the protection or enforcement of a specific right but an attempt to obtain an abstract determination of the amendment's validity, which federal courts are not empowered to provide.
Analysis:
This case is a foundational decision in the doctrine of standing, reinforcing the 'case or controversy' requirement of Article III. It establishes the principle that a generalized grievance, no matter how sincere, is insufficient to grant a plaintiff access to federal courts. By refusing to hear a case based on a citizen's abstract interest in constitutional governance, the Supreme Court limited the judicial role to resolving concrete disputes involving direct, personal injuries. This precedent has become a significant barrier to public interest litigation where plaintiffs cannot demonstrate a particularized harm, thereby shaping the scope of judicial power and reinforcing the separation of powers.
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