How does article 3 of the constitution relate to, the standing to sue? /////
Example text.
Quick keynotes in the Supreme Court’s unanimous decision in FDA v. Alliance for Hippocratic Medicine that “holds that the plaintiffs lack a legal right to challenge the FDA's actions regarding the regulation of mifepristone, the drug used in medication abortion.” · "Under Article III of the Constitution, a plaintiff's desire to make a drug less available for others does not establish standing to sue. Nor do the plaintiffs' other standing theories suffice… FDA is not requiring them to do or refrain from doing anything." · "Given the broad and comprehensive conscience protections guaranteed by federal law, the plaintiffs have not shown--and cannot show--that FDA's actions will cause them to suffer any conscience injury." · However, looking ahead, the Court avers that "is not clear that no one else would have standing to challenge FDA's relaxed regulation of mifepristone." First and foremost, kudos to the Administration and the FDA for the successful defense against what could have been an existential threat to our legal foundation for life science #innovation. The innovative and #patient communities’
Article III of the U.S. Constitution relates to standing to sue by requiring that a plaintiff must demonstrate a concrete and particularized injury to have standing. Standing is a crucial component in ensuring that federal courts only hear actual cases or controversies.
Keynotes from the Supreme Court's unanimous decision in FDA v. Alliance for Hippocratic Medicine:
Standing Requirement Under Article III: The Supreme Court highlighted that a plaintiff's desire to make a drug less available for others does not establish standing to sue. The plaintiffs must show a concrete injury directly resulting from the FDA's actions.
Insufficient Standing Theories: The Court rejected the plaintiffs' other theories of standing, noting that the FDA is not compelling them to do or refrain from doing anything. Thus, they are not suffering a direct injury.
Conscience Protections: Federal law provides broad and comprehensive conscience protections. The plaintiffs failed to demonstrate that the FDA's actions would cause them any conscience injury, which is necessary to establish standing.
Future Challenges: The Court acknowledged that although the current plaintiffs lack standing, it is not clear that no other parties could have standing to challenge the FDA's regulation of mifepristone in the future.
Commendation: The successful defense by the Administration and the FDA underscores the strength and resilience of the legal framework supporting life science innovation, benefiting both the innovative and patient communities.
Article III of the U.S. Constitution establishes the judicial branch of the federal government. It outlines the powers, structure, and jurisdiction of the federal courts. The key provisions related to standing to sue are found in Section 2, which states:
Judicial Power and Jurisdiction:
- The judicial power shall extend to all cases, in law and equity, arising under the Constitution, the laws of the United States, and treaties made under their authority.
- This power also covers cases affecting ambassadors, other public ministers and consuls, admiralty and maritime jurisdiction, controversies to which the United States is a party, and disputes between states, between a state and citizens of another state, between citizens of different states, and between citizens of the same state claiming lands under grants of different states.
Case or Controversy Requirement:
- The judicial power is limited to actual "cases" or "controversies," meaning that federal courts can only hear disputes involving specific, concrete legal issues where the plaintiff has suffered an actual injury that can be redressed by the court.
Here is the relevant text from Article III, Section 2:
"The judicial Power shall extend to all Cases, in Law and Equity, arising under this Constitution, the Laws of the United States, and Treaties made, or which shall be made, under their Authority;—to all Cases affecting Ambassadors, other public Ministers and Consuls;—to all Cases of admiralty and maritime Jurisdiction;—to Controversies to which the United States shall be a Party;—to Controversies between two or more States;—between a State and Citizens of another State;—between Citizens of different States;—between Citizens of the same State claiming Lands under Grants of different States, and between a State, or the Citizens thereof, and foreign States, Citizens or Subjects."
The requirement for a "case or controversy" means that the courts cannot issue advisory opinions or rule on hypothetical disputes; there must be a genuine dispute between parties with opposing legal interests.
This is the basis for the concept of standing, which requires plaintiffs to demonstrate a specific, concrete injury that is directly related to the action they are challenging.
Yes, the concept of "case" or "controversy" in Article III has been extensively interpreted and refined by the courts, particularly the Supreme Court, to ensure that federal judicial power is only exercised in genuine, concrete disputes where the parties have a significant stake in the outcome. This interpretation has led to the development of the doctrine of standing, which includes several key requirements:
Injury in Fact: The plaintiff must have suffered or be imminently threatened with a concrete and particularized injury that is actual or imminent, not hypothetical or conjectural.
Causation: There must be a direct causal connection between the injury and the conduct being challenged. The injury must be fairly traceable to the defendant's actions and not the result of actions by some third party not before the court.
Redressability: It must be likely, not merely speculative, that the injury will be redressed by a favorable court decision.
These requirements are designed to limit the types of disputes that federal courts can adjudicate, ensuring that they only resolve actual controversies where the parties have a real interest. This limitation prevents the courts from overstepping their constitutional role and encroaching on the functions of the legislative or executive branches.
In the context of the Supreme Court’s decision in FDA v. Alliance for Hippocratic Medicine, the Court found that the plaintiffs lacked standing because they could not demonstrate a sufficient injury in fact caused by the FDA’s regulation of mifepristone. Their desire to make the drug less available to others did not constitute a concrete and particularized injury that would give them the legal right to challenge the FDA’s actions.
Your observation is spot on.
While Article III of the Constitution provides the foundational requirement that federal courts only hear "cases" or "controversies," much of the detailed understanding of what constitutes a justiciable "case" has indeed been developed through over 200 years of common law and case law.
The Supreme Court and lower federal courts have interpreted and defined the contours of standing through numerous decisions, building a complex body of jurisprudence around this concept.
Here's a brief elaboration on how this body of law has evolved:
Development of Standing Doctrine
Early Interpretations: The concept of standing was not explicitly detailed in the early years of the Republic. The courts began to flesh out the requirement for a "case" or "controversy" to ensure they were not issuing advisory opinions or ruling on hypothetical questions.
Key Cases:
- Marbury v. Madison (1803): While more famous for establishing judicial review, this case also implicitly reinforced the need for an actual dispute for the Court to resolve.
- Frothingham v. Mellon (1923): The Court ruled that a taxpayer did not have standing to challenge federal expenditures, emphasizing the need for a direct, personal injury.
- Lujan v. Defenders of Wildlife (1992): This landmark case clarified the three-part test for standing (injury in fact, causation, redressability), which has become the standard framework used by the courts.
Refinement Over Time: The standing doctrine has been refined through numerous decisions, balancing the need to provide a forum for genuine grievances with the need to prevent the courts from being used for generalized policy disputes best handled by the legislative or executive branches.
Supreme Court's Interpretation in FDA v. Alliance for Hippocratic Medicine
In the decision regarding FDA v. Alliance for Hippocratic Medicine, the Court relied on this extensive body of case law to determine that the plaintiffs lacked standing. Their interpretation drew on established principles:
- Concrete and Particularized Injury: The plaintiffs could not show a specific, tangible injury resulting from the FDA's actions.
- Causal Connection: The Court found no direct causal link between the FDA's regulation and any injury suffered by the plaintiffs.
- Redressability: It was not clear that a court ruling would directly redress the alleged injury.
Conclusion
While Article III provides the constitutional basis for the requirement of a "case" or "controversy," the detailed rules and tests for standing have indeed been developed through extensive judicial interpretation over the centuries. The Supreme Court's reference to Article III in its decision is thus a shorthand for invoking this rich tradition of common law and case law that defines the limits of judicial power.
Exactly, interpreting the Constitution and deciding cases involves much more than just reading the text and making straightforward decisions.
As Chief Justice John Roberts once famously said, "Judges are like umpires. Umpires don't make the rules, they apply them." However, in practice, applying the rules often requires a deep understanding of legal precedents, nuanced interpretations of the law, and consideration of the broader implications of a decision.
In the context of standing to sue under Article III, the Supreme Court's decisions are informed by:
Historical Context: The framers' intent and historical practices that have shaped the judiciary's role over time.
Precedent: Hundreds of years of case law that have established principles and tests for determining standing, which go beyond the plain text of the Constitution.
Judicial Interpretation: Careful analysis and interpretation of legal concepts like "injury in fact," "causation," and "redressability," which have been developed through judicial reasoning and rulings.
Balancing Interests: Weighing individual rights against governmental interests, and considering the practical implications of judicial decisions on society and the legal system.
Therefore, while the Constitution provides the foundational framework, the actual practice of constitutional law requires much more nuanced and sophisticated analysis, drawing from a vast body of judicial decisions and legal thought.
