Valley Forge Christian College v. Americans United for Separation of Church & State

Valley Forge Christian College v. Americans United for Separation of Church and State
Supreme Court of the United States
Argued November 4, 1981 Decided January 12, 1982
Full case name	Valley Forge Christian College v. Americans United for Separation of Church and State
Citations	454 U.S. 464 (more) 102 S. Ct. 752; 70 L. Ed. 2d 700; 1982 U.S. LEXIS 22
Case history
Prior	619 F.2d 252 (reversed)
Holding
The Court decided that the taxpayers did not meet the requirements of the first prong of the double nexus test put forth in Flast as they did not argue a violation of Art. 1 Sec. 8 (taxing and spending) occurred.
Court membership
Chief Justice Warren E. Burger Associate Justices William J. Brennan Jr. · Byron White Thurgood Marshall · Harry Blackmun Lewis F. Powell Jr. · William Rehnquist John P. Stevens · Sandra Day O'Connor
Case opinions
Majority	Rehnquist, joined by Burger, White, Powell, O'Connor
Dissent	Brennan, joined by Marshall, Blackmun
Dissent	Stevens
Laws applied
U.S. Constitution, Art. I, Sec. 8, Art. III;

Valley Forge Christian College v. Americans United for Separation of Church and State, 454 U.S. 464 (1982), was a decision by the Supreme Court of the United States in which the court refused to expand the Flast v. Cohen exception to the taxpayer standing rule.

The Department of Health, Education, and Welfare had disposed of surplus property by conveying it, without charge, to a church-related college.

Plaintiffs sought standing as taxpayers, and alternatively as citizens, claiming that the conveyance of property injured their right to a government that does not establish a religion.

Justice Rehnquist, writing the majority opinion, upheld the Flast test for taxpayer standing, ruling that plaintiffs lacked standing as taxpayers because they did not challenge an exercise of the Spending Clause. He also rejected the theory of standing as citizens. He held that the court is not merely a forum for "public grievances" brought by "concerned bystanders"; if it were, he reasoned, "the concept of 'standing' would be quite unnecessary".

Justice Brennan, in his dissent, criticized the general prohibition on taxpayer standing established by Frothingham v. Mellon, arguing that standing should not be denied "simply because many people suffer the same injury" or because the injury is indirect. Justice Stevens, in his dissent, called "the difference between a disposition of funds pursuant to the Spending Clause and a disposition of realty pursuant to the Property Clause", "a tenuous distinction".

See also

• List of United States Supreme Court cases, volume 454
• Hein v. Freedom From Religion Foundation

References

American Constitutional Law: Powers and Liberties. Massey

External links

• Text of Valley Forge Christian College v. Americans United for Separation of Church and State, 454 U.S. 464 (1982) is available from: Cornell  CourtListener  Findlaw  Google Scholar  Justia  OpenJurist  Oyez (oral argument audio) 

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This page was last edited on 13 September 2023, at 03:23