Singleton v. Wulff, 428 U.S. 106 (1976)
Standing arises if the person bringing a case to assert the rights of a third party has a close relationship with that third party, and the third party has obstacles preventing it from suing on its own behalf.
Missouri did not make Medicaid benefits available to eligible individuals on the basis of abortions that were not medically indicated. Two doctors in Missouri, including Wulff, did perform non-medically indicated abortions for women who were qualified to receive Medicaid. They sued a state health official, Wulff, on the grounds that the law unconstitutionally infringed on the reproductive rights of women. The state responded that they did not have standing to bring this action.Opinions
- Harry Andrew Blackmun (Author)
- William Joseph Brennan, Jr.
- Byron Raymond White
- Thurgood Marshall
Plaintiffs must have a sufficiently concrete interest in the outcome of the litigation to satisfy the injury in fact requirement necessary to establish standing. The doctors would benefit from a positive result in the case by being paid for the abortions, while the state would lose that amount of funds. Although they represented the constitutional rights of the women, who were third parties, the doctors still should be granted standing as a prudential matter because the justification for the ban on third-party standing is irrelevant here. The confidential physician-patient relationship supports the doctor's right to bring a constitutional claim. Without the assistance of a doctor who is paid by the state, a woman likely cannot receive an abortion. A woman's concern over her privacy, however, may make her reluctant to bring this action on her own behalf, and any case that a woman brings may become moot if she is forced to give birth to the child for lack of funds to obtain an abortion.
- John Paul Stevens (Author)
- Lewis Franklin Powell, Jr. (Author)
- Warren Earl Burger
- Potter Stewart
- William Hubbs Rehnquist
There are three main exceptions to the standing rule against third-party standing: when the third party faces genuine obstacles to suing on its own behalf, when the rights asserted by the litigant and the third party are very similar, and when a law is constitutionally overly broad but is not unconstitutional as applied to the party challenging it.
U.S. Supreme CourtSingleton v. Wulff, 428 U.S. 106 (1976)
Singleton v. Wulff
Argued March 23, 1976
Decided July l, 1976
428 U.S. 106
Respondents, two Missouri-licensed physicians, brought this action for injunctive relief and a declaration of the unconstitutionality of a Missouri statute that excludes abortions that are not "medically indicated" from the purposes for which Medicaid benefits are available to needy persons. In response to petitioner's pre-answer motion to dismiss, each respondent averred that he had provided, and anticipated providing, abortions to needy patients, and that petitioner, the responsible state official, acting in reliance on the challenged statute, had refused all Medicaid applications filed in connection with such abortions. A three-judge District Court dismissed the relevant count of the complaint for lack of standing, having concluded that no logical nexus existed between the status asserted by respondents and the claim that they sought to have adjudicated. The Court of Appeals reversed, finding that respondents had alleged sufficient "injury in fact" and also an interest "arguably within the zone of interests to be protected . . . by the . . . constitutional guarantees in question." That court then considered the case on the merits and found that the challenged statute clearly violated the Equal Protection Clause.
508 F.2d 1211, reversed and remanded.
MR. JUSTICES BLACKMUN delivered the opinion of the Court with respect to Parts I, II-A, and III, finding that:
1. Respondents had standing to maintain this suit. Respondents alleged "injury in fact," i.e., a sufficiently concrete interest in the outcome of their suit to make it a case or controversy subject to the District Court's Art. III jurisdiction. If respondent physicians prevail in their suit to remove the statutory limitation on reimbursable abortions, they will benefit by receiving
payment for the abortions and the State will be out of pocket by the amount of the payments. Pp. 428 U. S. 112-113.
2. The Court of Appeals should not have proceeded to resolve the merits of this case, since petitioner, who has not filed an answer or other pleading addressed to the merits, has not had the opportunity to present evidence or legal arguments in defense of the statute. Pp. 428 U. S. 119-121.
MR. JUSTICE BLACKMUN, joined by MR. JUSTICE BRENNAN, MR. JUSTICE WHITE, and MR. JUSTICE MARSHALL, concluded, in Part II-B, that, as a prudential matter, respondents are proper proponents of the particular rights on which they base their suit. Though "[o]rdinarily, one may not claim standing . . . to vindicate the constitutional rights of some third party," Barrows v. Jackson, 346 U. S. 249, 346 U. S. 255, here the underlying justification for that rule is absent. A woman cannot safely secure an abortion without a physician's aid, and an impecunious woman cannot easily secure an abortion without the physician's being paid by the State. Aside from the woman herself, the physician is uniquely qualified, by virtue of his confidential, professional relationship with her, to litigate the constitutionality of the State's interference with, or discrimination against, the abortion decision. Moreover, there are obstacles to the woman's assertion of her own rights, in that the desire to protect her privacy may deter her from herself bringing suit, and her claim will soon become at least technically moot if her indigency forces her to forgo the abortion. Pp. 428 U. S. 113-118.
BLACKMUN, J., announced the judgment of the Court and delivered an opinion of the Court with respect to Parts I, II-A, and III, in which all Members joined, and in which, as to Part II-B, BRENNAN, WHITE, and MARSHALL, JJ., joined. STEVENS, J., filed an opinion concurring in part, post, p. 428 U. S. 121. POWELL, J., filed an opinion concurring in part and dissenting in part, in which BURGER, C.J., and STEWART and REHNQUIST, JJ., joined, post, p. 428 U. S. 122.