Summary of Raines v. Byrd
S. Ct. (1997)
Relevant Facts: Appellees are six members of Congress, four senators and two representatives. The Senate passed a bill, Line Item Veto Act, in 1996. The next day the House passed the same bill and the President signed the bill into law. The Act went into effect the following January. The Act states that the President may cancel certain spending and tax benefit measures after he has signed them into law.
Legal Issue(s): Whether each of the Appellees, plaintiffs initially, has standing to sue? Is the claimed injury personal, particularized, concrete, and otherwise judicially cognizable?
Court’s Holding: No, the appellees lack standing to sue.
Law or Rule(s): Article III U.S. Constitution, the asserted injury was the consequence of the defendant’s actions, or that prospective relief will remove the injury. Case or controversy requirement. Is the claimed injury personal, particularized, concrete, and otherwise judicially cognizable?
Procedure: District Court issued judgment in favor of appellees/plaintiffs and the S. Ct. vacated and dismissed.
Court Rationale: Ct. will not address the merits of the case before addressing the standing issue. Appellee’s claim of standing is based on the loss of political power, not the loss of a private right. Their injury is not the diminution of legislative power or an institutional injury, but rather the injury is merely an unfavorable vote, of which may be reversed by Congress at a later date. The Appellees would like this court to determine the separation of powers to their favor. That is not the court’ prerogative unless it is of last resort.
Plaintiff’s Argument: The procedure allows the President to nullify each Senator and Representative’s vote not in accordance with the President’s wishes, after he had passed the bill into law. Therefor the Senators and Representative have suffered an concrete injury, i.e. deprivation of a Constitutional right.
Defendant’s Argument: The injury claimed here is not of a personal nature, but of a political one originating out of official interest.