DaimlerChrysler Corp. v. Cuno

Article III requires a plaintiff to show a personal injury that is concrete and particularized, fairly traceable to the defendant's conduct, and likely redressable by judicial relief. The plaintiffs' claimed injury—that the credit depleted Ohio's treasury and thereby imposed disproportionate tax burdens on them—was a generalized grievance shared indistinctly with other taxpayers, not a particularized injury to these plaintiffs.

The Court treated a tax credit that allegedly reduces revenue in the same way it treats a direct government expenditure for taxpayer-standing purposes. In either situation, a taxpayer's alleged injury depends on an asserted effect on the public fisc, an interest that is too remote, uncertain, and widely shared to satisfy Article III.

The asserted injury and redressability were also speculative. It was uncertain whether the credit actually reduced revenue, because an incentive designed to stimulate economic activity may increase overall revenues. Even if revenue fell, the plaintiffs had to speculate that legislators would raise their taxes to make up the difference; and, if the credit were invalidated, they had to speculate that legislators would use any additional revenue to reduce their taxes or fund programs benefiting them.

Frothingham v. Mellon and Doremus v. Board of Education established that generalized taxpayer objections to governmental fiscal choices do not create a justiciable case or controversy. Extending taxpayer standing to state fiscal decisions would improperly place federal courts in the role of continuing monitors of state budgets and policy judgments.

Flast allows certain taxpayer suits alleging that Congress used its taxing and spending power in violation of the Establishment Clause. The exception rests on the historical understanding that compelled financial support of religion is itself the constitutional injury: the taxpayer challenges the extraction and spending of tax money in aid of religion.

A Commerce Clause objection is fundamentally different. The plaintiffs' asserted harm still depended on predictions about the fiscal consequences of the credit and the legislature's future allocation of revenues. Invalidating the credit would not itself redress a personal injury comparable to compelled support for religion.

The Court declined to equate the Commerce Clause and Establishment Clause at a high level of abstraction, such as both requiring governmental neutrality. Doing so would make it difficult to distinguish other constitutional provisions that constrain governmental tax and spending decisions, contrary to Flast's consistently narrow application.

Municipal taxpayers may, in limited circumstances, challenge an illegal use of their municipality's funds because of their distinctive relationship to the municipal corporation. But the franchise-tax credit was a state action, not a municipal action. The plaintiffs could not convert a challenge to a state tax measure into a municipal-taxpayer claim merely because municipalities might receive some state revenue.

Any claimed effect on municipal finances was especially conjectural. Although Ohio law had provided for distribution of franchise-tax revenues to local governments, the General Assembly had suspended that distribution mechanism. Thus any benefit to local governments from invalidating the credit would depend on a discretionary future decision by state officials, not an automatic statutory consequence.

Supplemental jurisdiction under United Mine Workers v. Gibbs could not cure a plaintiff's lack of constitutional standing on a separate claim. A plaintiff must establish standing for each claim and each form of relief sought; standing is not dispensed in gross simply because claims share a common nucleus of operative fact.

Because the plaintiffs lacked standing to challenge the franchise-tax credit, the lower courts should not have reached its Commerce Clause validity. The Court vacated the Sixth Circuit's ruling on that credit and remanded for dismissal of that challenge.