Summary of Frothingham v. Mellon
Relevant Facts: Frothingham v. Mellon and Massachusetts v. Mellon were heard together by the Supreme Court. The premise of each case was the fact that the state of Massachusetts along with private individuals (citizens) asked the Court to stop federal funds from being used for the Maternity Act. The Maternity Act (Sheppard-Towner Act) was an act geared towards securing funds and thus services to reduce infant and maternal mortality, among other things. It was one of the beginning pieces of legislation to be considered progressive in the moniker of “social security" in the 20th century. The challenge to the act was premised on the argument that the expenditures emanated from an additional taxation on the People, and violated the Tenth Amendment by virtue of it being a deprivation or seizure of property (tax funds) without due process.
Issues: The legal question presented was whether the expenditures required for the act in fact constituted a Tenth Amendment violation.
Holding: No. The Supreme Court unanimously decided to dismiss the case. Massachusetts’ suit to refuse funding (along with other private petitioners) was dismissed because the state did, after all, have the option to refuse the federal funding reserved for the provision of the program at the state level. For the individual petitioners, there had been no proof of rights being denied without due process – Frothingham had failed to demonstrate a direct injury since the nature of taxation is inherently public, any burden upon him would be “comparatively minute and indeterminable.” Ultimately, the Court dismissed the case and refused to review its merits because there was no actual controversy (the State) in addition to a lack of standing (the private/individual petitioners).
Conclusion: This case was significant because these represented the first challenges to a federal-based social welfare program meant to address social ills by the redistribution of funds via taxation. The Court never addressed this issue since it decided to dismiss the case, but this theme continued throughout later cases, at which points the Court has ruled upon this and similar issues.