No. The Court decided that neither the state nor the taxpayer had a good enough reason to bring a lawsuit. For Massachusetts, the law didn't force the state to do anything; it just made an offer of money that the state could easily refuse. Because there was no direct harm, the state's complaint was a political argument, not something for a court to decide. For Ms. Frothingham, her share of the tax money being spent was incredibly tiny and impossible to calculate. To sue, you have to show you've suffered a real, direct injury, not just a general complaint that every other taxpayer in the country could make.

No, neither Massachusetts nor Frothingham can sue about this law. Here's why: The Court can't even look at whether the law is good or bad because neither Massachusetts nor Frothingham has the right kind of problem to bring to court. Massachusetts isn't being forced to do anything by this law - it can take the money or leave it. Also, Massachusetts can't fight for its citizens against the federal government in this situation - that's not its job. Frothingham's problem is too small and unclear. She's just one of millions of taxpayers, and we can't say for sure how this law affects her taxes. If we let her sue, then anyone could sue about any government spending they don't like, which would be too much for the courts to handle. Our job as judges is to solve real legal problems, not to check every decision the government makes about spending money just because some people don't like it.

The party who invokes the power [of judicial review] must be able to show, not only that the statute is invalid, but that he has sustained or is immediately in danger of sustaining some direct injury as the result of its enforcement, and not merely that he suffers in some indefinite way in common with people generally.

—holding that federal taxpayers have no standing to challenge the unconstitutional use of their tax dollars

A core component of that judicial power is " `the duty of interpreting [the laws] and applying them in cases properly brought before the courts

While the State, under some circumstances, may sue in that capacity for the protection of its citizens, it is no part of its duty or power to enforce their rights in respect of their relations with the Federal Government. In that field it is the United States, and not the State, which represents them as parens patriae

—people generally.... Here the parties plaintiff have no such case....[T] heir complaint... is merely that officials of the executive department of the government are executing and will execute an act of Congress asserted to be unconstitutional; and this we are asked to prevent. To do so would be not to decide a judicial controversy, but to assume a position of authority over the …

—holding that a taxpayer's "interest in the moneys of the Treasury... is shared with millions of others; is comparatively minute and indeterminable; and the effect upon future taxation, of any payment out of the funds, so remote, fluctuating and uncertain, that no basis is afforded" for standing

It derives from Supreme Court cases that predate the Court's modern approach to standing, as stated in cases such as Lujan. See id

Even though its action may result in the disadvantages and embarrassments of keeping open doubtful questions of constitutionality, this Court will consider only those very limited aspects of a statute that alone may affect the rights of a particular litigant before the Court.

Indeed, even if the Board were permitted to sue on behalf of Township residents as parens patriae, its claims likely would be barred because departments of the federal government are named as defendants.

No. Neither a State nor an individual federal taxpayer has standing to challenge the constitutionality of a federal spending statute under these circumstances. For a plaintiff to have standing, they must demonstrate a direct injury, not a generalized grievance. Regarding Massachusetts, the Maternity Act imposes no obligation on the state; it merely presents a voluntary option which the state is free to accept or reject. The state's complaint that Congress has usurped reserved powers is an abstract political question, not a justiciable controversy involving the state's proprietary or quasi-sovereign rights. The state cannot sue as *parens patriae* on behalf of its citizens against the federal government, because in that relationship, the United States itself acts as *parens patriae*. Regarding Frothingham, a federal taxpayer's interest in the U.S. Treasury is 'comparatively minute and indeterminable' and is shared with millions of others. The effect of a single appropriation on her future tax liability is too 'remote, fluctuating and uncertain' to constitute the direct injury necessary for standing. Allowing such suits would open the courts to innumerable challenges over any federal expenditure and would represent a judicial intrusion into the powers of the legislative and executive branches.

No. Neither the State of Massachusetts nor the individual taxpayer has standing to challenge the Maternity Act. I conclude this because the cases must be disposed of for want of jurisdiction without considering the merits of the constitutional questions. The State of Massachusetts does not present a justiciable controversy either in its own behalf or as the representative of its citizens. The Maternity Act does not invade the powers of the State or impose any burden, as it merely extends an option that the State is free to accept or reject. The alleged usurpation of power is a political question outside the scope of judicial power. Massachusetts cannot sue as parens patriae on behalf of its citizens against the federal government, as it is the United States, not the State, that represents citizens in matters involving the federal government. Frothingham lacks standing as a taxpayer to challenge federal appropriations because her interest in the Treasury is too remote, indeterminate, and shared with millions of others, making her alleged injury too minute for judicial consideration. The Court's role is to interpret and apply laws in proper cases, not to engage in overseeing the execution of statutes based on generalized grievances. To allow such suits would potentially open the floodgates to countless challenges to federal appropriations, which is not the function of the judiciary.

Massachusetts v. Mellon

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