Singleton v. Wulff Case Brief

Why is the case important?

Two Missouri physicians sued the state, charging that Missouri’s statute prohibiting Medicaid payments for abortions which are not “medically indicated” unconstitutionally interferes with the decision to terminate a pregnancy.

Facts of the case

Question

Do the physicians have standing to bring the suit when the immediately affected are indigent women seeking abortions?

Answer

Yes. Court of appeals ruling affirmed.
Two standing questions were presented: (i) whether plaintiff sustained injury in fact and (ii) whether they are the proper individuals to assert the constitutional right in question. The first question is easily answered. Here, the physicians have been denied compensation and stand to be denied further compensation.
As to the second question, the general rule of prohibiting third-party standing only applies if the relationship between the litigant and the party directly affected is such that the litigant does not effectively serve as a proponent of the affected party and if there is some impediment to the affected party bringing suit himself. Here, the litigant was deemed to effectively serve as a proponent.

Conclusion

The Court affirmed the physicians’ standing, holding that there was adequate injury asserted for the physicians to bring a claim. The Court held that the physicians were qualified to litigate the constitutionality of the Chief’s interference with, or discrimination against, an abortion funding decision, because there were significant obstacles that could have prevented women patients from litigating. Nevertheless, the Court held that the appellate court erred by determining the claim on its merits when the Chief had not presented evidence but only filed a motion for dismissal. Injustice was more likely to be caused than avoided by deciding the issue without the Chief’s having had an opportunity to be heard.

  • Case Brief: 1976
  • Petitioner: Singleton
  • Respondent: Wulff
  • Decided by: Burger Court

Citation: 428 US 106 (1976)
Argued: Mar 23, 1976
Decided: Jul 1, 1976