## Facts

- Congress proposed the Nineteenth Amendment in 1919; by July 1920, thirty-five states had ratified and one additional ratification would complete adoption.
- Charles S. Fairchild, a New York citizen and taxpayer, sued the Secretary of State and the Attorney General in the Supreme Court of the District of Columbia.
- Fairchild sought (1) a declaration that the Nineteenth Amendment was unconstitutional and void, (2) an injunction barring the Secretary of State from proclaiming its ratification, and (3) an injunction barring the Attorney General from enforcing it or any related federal criminal legislation.
- At the time suit was filed, the proclamation had not issued, and anticipated enforcement was contingent on future events.
- New York already permitted women to vote, limiting any claim that the amendment would alter Fairchild’s own voting rights.
- The D.C. trial court dismissed; the Court of Appeals of the District of Columbia affirmed; the Supreme Court noted probable jurisdiction and reviewed the case.

## Issues

1. Whether a citizen and taxpayer with only a generalized interest in lawful government has standing to challenge the ratification and prospective proclamation/enforcement of a constitutional amendment.
2. Whether an equity suit seeking to prevent prospective governmental action, absent a concrete personal injury, presents a “case” or “controversy” within Article III.

## Decision

- The Supreme Court affirmed the decree dismissing the bill for want of jurisdiction.
- The Court held that Fairchild alleged no concrete, personal legal injury and therefore lacked standing.
- The Court concluded the suit was not a justiciable “case” within Article III because it sought an abstract determination of the validity of a constitutional amendment process.

## Legal Principles

- A generalized citizen interest in having the government administered according to law and public funds not wasted does not confer standing in federal court.
- Federal judicial power extends only to Article III “cases” and “controversies,” not requests for abstract or advisory determinations of prospective validity.
- Claims based on speculative, contingent future effects of governmental action are insufficient to establish a justiciable dispute.

## Conclusion

The Court denied jurisdiction because the plaintiff asserted only a generalized grievance and speculative future harms, reinforcing that federal courts may not adjudicate challenges to prospective governmental action without a concrete, personal injury establishing an Article III case or controversy.


Fairchild v. Hughes, 258 U.S. 126 (1922)