Caseflicks

Supreme Court of the United States • 1937

Ex parte Lévitt

302 U.S. 633 | 58 S. Ct. 1

Full access

Unlock the video and quiz

The written brief is free to read below. Subscribe to watch the video explainer and take the quiz.

Takeaway

In short, this case states the foundational standing rule that a private citizen cannot litigate a generalized grievance about government action without alleging a direct, personal injury.

Background

Albert Lévitt, appearing pro se, moved for leave to file a petition seeking an order requiring Hugo Black to show cause why he could serve as an Associate Justice of the Supreme Court.

Lévitt alleged that Justice Black's appointment by the President and confirmation by the Senate were invalid. He asserted that Black was constitutionally ineligible under Article I, Section 6, Clause 2, and that no lawful vacancy existed for the appointment. There was no lower-court decision; the matter came directly to the Supreme Court as a motion for leave to file the proposed petition.

The motion papers showed that Lévitt claimed no personal stake beyond his status as a citizen and a member of the Supreme Court bar.

Issues

Issue #1

Whether a citizen and member of the Supreme Court bar, without a claimed personal injury, may invoke the Court's judicial power to challenge the validity of a Justice's appointment.

Holding

No. Lévitt's generalized interest as a citizen and member of the bar was insufficient, so the Court denied leave to file the petition.

Reasoning

The Court treated the threshold question as one of entitlement to invoke the federal judicial power. A private person must show that the challenged executive or legislative action has caused, or immediately threatens to cause, a direct injury to that person.

Lévitt identified no injury peculiar to himself. His asserted interest in the constitutional validity of Justice Black's appointment was shared generally by the public and was therefore not enough to support judicial review.

Because Lévitt lacked the required direct personal stake, the Court did not reach his claims that the Ineligibility Clause barred the appointment or that no vacancy existed. The motion was denied on that threshold ground.