Facts
- Congress enacted the Line Item Veto Act of 1996, authorizing the President, after signing a bill into law, to cancel specified spending items and limited tax benefits subject to statutory findings and notice to Congress.
- Six Members of the 104th Congress (four Senators and two Representatives) voted against the Act.
- The day after the Act took effect, the Members sued executive-branch officials in federal district court, alleging the Act was unconstitutional under the Presentment Clause and as an improper delegation of legislative power.
- The Members alleged their injury was the dilution of their Article I voting power and a shift in legislative power toward the President.
- The district court denied the government’s motion to dismiss for lack of standing, held the case ripe despite no presidential cancellations yet, and entered judgment for the Members on the merits.
Issues
- Whether individual Members of Congress have Article III standing to challenge a federal statute based on an asserted institutional diminution of legislative power shared equally by all Members.
- Whether an alleged “dilution” of legislators’ voting power, without personal exclusion or other individualized harm, constitutes a concrete and particularized injury in fact.
Decision
- The Supreme Court vacated the district court’s judgment and remanded with instructions to dismiss for lack of jurisdiction.
- The Court held the Member-plaintiffs lacked Article III standing because they alleged no personal, particularized, and concrete injury.
- The asserted harm was characterized as an abstract, institutional injury affecting all Members of Congress equally, not a personal deprivation such as loss of office or denial of a seat.
- The Court emphasized that standing analysis is especially demanding where adjudication would require resolving a separation-of-powers dispute between branches.
- The Court noted that if the cancellation authority were exercised, parties directly affected by cancellations would be more likely to have the concrete injury necessary for judicial review.
Legal Principles
- Article III requires a plaintiff to allege an injury in fact that is personal, concrete, and particularized; institutional grievances shared in equal measure by legislators generally do not satisfy this requirement.
- Courts apply standing requirements with special rigor when the requested relief would entail deciding whether another federal branch acted unconstitutionally.
- Legislator standing is not established by a claim that a statute generally reduces the effectiveness of legislators’ votes; individualized harms such as exclusion from office are materially different.
- Institutional interests of Congress are ordinarily addressed through political processes rather than suits by individual legislators, absent a distinct personal injury.
Conclusion
The Court dismissed the suit for lack of standing, holding that individual legislators cannot invoke federal jurisdiction based solely on an alleged, generalized dilution of Congress’s institutional power, thereby avoiding a merits ruling on the statute’s constitutionality.