## Facts

- Williamsport High School students formed a religious club (“Petros”) and sought permission to meet on school premises during student activity periods.
- The principal referred the request to the superintendent, who denied it based on the school district solicitor’s opinion; the school board upheld the denial.
- Ten students sued the school district, individual school board members, the superintendent, and the principal, alleging the denial (based on religious activity) violated the First Amendment and seeking declaratory and injunctive relief.
- The district court granted summary judgment for the students, issued declaratory relief, entered no injunction, and granted no relief against any defendant in an individual capacity.
- The school district complied with the judgment and did not appeal.
- One school board member (Youngman) alone filed a notice of appeal; the court of appeals reached the merits and reversed.
- The Supreme Court granted certiorari to address whether Youngman had standing to invoke appellate jurisdiction.

## Issues

1. Whether an individual member of a multi-member school board has Article III standing to appeal an adverse declaratory judgment when the board and school district accept the judgment and do not appeal.
2. Whether the same individual could establish appellate standing by asserting parental status when he did not litigate or intervene as a parent in the district court.
3. What disposition is required when a federal appellate court decides the merits without jurisdiction due to the appellant’s lack of standing.

## Decision

- The Supreme Court dismissed the writ of certiorari and remanded with instructions to vacate the court of appeals’ judgment and dismiss the appeal for lack of jurisdiction.
- Youngman lacked standing to appeal in an individual capacity because the judgment imposed no personal liability or personal legal obligations on him.
- Youngman lacked standing to appeal in an official capacity because a single member of a collegial governmental body generally cannot assert the entity’s institutional interests when the entity itself declines to appeal.
- Youngman lacked standing to appeal as a parent because the record did not establish parental injury and he did not participate in the litigation in that capacity.
- Because Youngman lacked standing, the court of appeals lacked jurisdiction to decide the merits, and its judgment had to be vacated; the district court’s unappealed declaratory judgment remained in place.

## Legal Principles

- Article III standing requires a litigant to show a personal, concrete injury that is traceable to the challenged action and likely to be redressed by the requested relief.
- Federal appellate courts have an independent obligation to examine jurisdiction, including standing, even if the parties do not raise the issue.
- Members of multi-member (collegial) governmental bodies generally do not have standing to pursue an appeal on behalf of the body when the body itself chooses not to appeal.
- A party cannot typically cure a standing defect on appeal by asserting a new litigating capacity (such as parent) that was not established in the record or pursued in the trial court.

## Conclusion

The Court held that a lone school board member could not invoke federal appellate jurisdiction to challenge a declaratory judgment the board and district accepted, requiring vacatur of the appellate merits decision and dismissal of the appeal for lack of Article III standing.


Bender v. Williamsport Area Sch. Dist., 475 U.S. 534 (1986)