Allen v. Wright Case Brief

Facts of the case

In an effort to curb racially discriminatory practices in private schools, the Internal Revenue Code denies tax-exempt status to schools which promote such practices. The Code also prohibits individuals from making tax-deductible donations to private schools which racially discriminate. Inez Wright and others filed a nationwide class action suit arguing that the IRS had not fulfilled its obligations in enforcing these provisions of the Code, and thus, that government was subsidizing and encouraging the expansion of segregated education in private schools. This case was decided together with Reagan v. Wright.

Why is the case important?

Parents of black public school children brought suit against the Internal Revenue Service (“IRS”), alleging that insufficient denial of tax-exempt status to racially discriminatory private schools interferes with their children’s ability to receive an education in public schools.

Question

Does the harm alleged by the respondents fulfill the constitutional requirement of standing?

ANSWER

No. Reversed and remanded.
Addressing the first allegation, Justice Sandra Day O’Connor (J. O’Connor) notes “an asserted right to have the government act in accordance with the law” is insufficient to grant jurisdiction. Extending this line of argument, she says “[a] black person in Hawaii could challenge the grant of a tax exemption to a racially discriminatory school in Maine.” Furthermore, the issue of funding the schools does not harm the respondents directly.
The second allegation does present harm, that the respondents’ children are being denied an integrated educational experience. However, the IRS’s actions are too far attenuated from this harm. There is no evidence that denying tax-exempt status to the private schools in question would result in a more integrated public education system.

CONCLUSION

The first basis for standing alleged by respondents, that they were harmed directly by the mere fact of government financial aid to discriminatory private schools, did not constitute a judicially cognizable injury and their second basis, that their children were being deprived of an opportunity to receive an education in racially integrated schools, although a judicially cognizable injury, was not fairly traceable to the government conduct that respondents challenged as unlawful.

  • Advocates: Robert H. Kapp Argued the cause for the respondents Rex E. Lee Argued the cause for the petitioners in No. 81-970 William J. Landers, II Argued the cause for the petitioner in No. 81-757
  • Petitioner: Allen
  • Respondent: Wright
  • DECIDED BY:Burger Court
  • Location: Briarcrest Christian Academy
Citation: 468 US 737 (1984)
Argued: Feb 29, 1984
Decided: Jul 3, 1984
Allen v. Wright Case Brief