Raines v. Byrd Case Brief

Why is the case important?

Four senators (P) and two congressmen (P) voted against the Line Item Veto Act of 1996. Later they filed a suit against the Act on the grounds that it violated the constitution.

Facts of the case

Several individual members of the 104th Congress, who voted against the passage of the Line Item Veto Act (Act) giving the President authority to veto individual tax and spending measures after having signed them into law, sued to challenge the Act’s constitutionality. After granting them standing, the District Court ruled in the congressmen’s favor as it found the Act unconstitutional. Direct appeal was granted to the Supreme Court.

Question

Do Congress members whose votes for or against a bill have been recognized with full effect have legal standing to file suit against the constitutionality of the bill?

Answer

(Rehnquist, C.J.) No. Members of Congress whose votes for or against a bill have been accepted have no standing to challenge its constitutionality in court. For a federal court to have jurisdiction over a dispute, there must be an injury cognizable under law and a genuine dispute. The Supreme Court had previously declared that legislators had standing to claim an injury to the legislature as an institution, in the case of Coleman v. Miller, 307 U.S. 433 (1939), that case had to do with the invalidation of their voting power. In this case, the congressmen were allowed to exercise full voting rights but lost in the voting. It is the dilution of the voting power of the legislation as an abstract possibility which is the issue here, in contrast to Coleman where the members had truly lost their voting power. This abstract risk does not amount to a real personal injury and so the members (P) have no standing in the case as suitors. They could still repeal the Act. Another option is for a member who suffers an injury under law as a consequence of the operation of the Act to file a case against it as being unconstitutional. The suit was vacated and remanded with instructions to the lower court to dismiss the complaint

Conclusion

The Supreme Court reversed, holding that the Congress members lacked standing because they did not allege they had been individually or concretely harmed by the Act, only that official congressional power as a whole was affected. The Congress members had not voted for a bill that was affected by the Act. Congress’ power to enact or repeal bills was not affected. Congress approved the Act and was also able to repeal it if it desired.

  • Case Brief: 1997
  • Appellant: Raines
  • Appellee: Byrd
  • Decided by: Rehnquist Court

Citation: 521 US 811 (1997)
Argued: May 27, 1997
Decided: Jun 26, 1997