holding that indigent plaintiffs, who alleged that a regulation affording favorable tax treatment to certain hospitals that provided only limited services to indigent patients "encouraged" those hospitals to deny them service, lacked standing to challenge the regulation, reasoning that it was "purely speculative whether the denials of service specified in the complaint fairly [could] be traced" to the regulation or "instead result[ed] from decisions made by the hospitals without regard to the tax implications" and that it was "equally speculative" whether the plaintiffs' desired injunction would result in them receiving service
How later courts described this case
- holding that indigent plaintiffs, who alleged that a regulation affording favorable tax treatment to certain hospitals that provided only limited services to indigent patients "encouraged" those hospitals to deny them service, lacked standing to challenge the regulation, reasoning that it was "purely speculative whether the denials of service specified in the complaint fairly [could] be traced" to the regulation or "instead result[ed] from decisions made by the hospitals without regard to the tax implications" and that it was "equally speculative" whether the plaintiffs' desired injunction would result in them receiving service
- holding, in a challenge to an IRS revenue ruling allowing favorable tax treatment to nonprofit hospitals that offered indigents only emergency room service, that the plaintiffs failed to establish redressability where, if such treatment were rescinded, it was "just as plausible that the hospitals to which [the plaintiffs] may apply for service would elect to forgo favorable tax treatment to avoid the undetermined financial drain of an increase in the level of uncompensated services" as it was that the "suit would result in the availability to [the plaintiffs] of such services"
- holding that an IRS Revenue Ruling "allowing favorable tax treatment to a nonprofit hospital that offered only emergency-room services to indigents" did not cause hospitals to deny other services to indigents because "[i]t is purely speculative whether the denials... fairly can be traced to [the Ruling] or instead result[ed] from decisions made by the hospitals without regard to the tax implications"
- holding the indigent plaintiffs lacked standing to challenge an Internal Revenue Service Ruling that provided favorable tax treatment to hospitals who denied certain services to indigents, because it was “purely speculative” whether the denials of service could be traced to the Revenue Ruling or, instead, to decisions made by the hospitals without regard to any tax implications
Written by the judges who cited it.
Distinguished
Distinguished by State v. U.S. Dep't of Commerce, 315 F. Supp. 3d 766 (2018)
Moreover, Clapper and Simon are distinguishable.
Distinguished by Clinton v. City of New York, 524 U.S. 417 (1998)
Allen v. Wright, 468 U. S. 737 (1984), and Simon v. Eastern Ky. Welfare Rights Organization, 426 U. S. 26 (1976), are distinguishable, as each of those cases involved a speculative chain of causation quite different from the situation here.
Distinguished by Allen v. Wright, 468 U.S. 737 (1984)
The court concluded, however, that the Simon case is inapposite because respondents claim no injury dependent on taxpayers’ actions: “[t]hey claim indifference as to the course private schools would take.
The opinion
Mr. Justice Stewart,
concurring.
I join the opinion of the Court holding that the plaintiffs in this case did not have standing to sue. I add only that I cannot now imagine a case, at least outside the First Amendment area, where a person whose own tax liability was not affected ever could have standing to litigate the federal tax liability of someone else.