Flast v. Cohen case brief

Flast v. Cohen case brief summary
392 U.S. 83 (1968)

CASE SYNOPSIS

Appellant taxpayers sought review of a judgment from the United States District Court for the Southern District of New York, which dismissed their complaint on the ground that appellants lacked standing. Appellants had filed suit in the court to enjoin the allegedly unconstitutional expenditure of federal funds under Titles I and II of the Elementary and Secondary Education Act of 1965, 20 U.S.C.S. §§ 241a et seq., §§ 821 et seq.

DISCUSSION

• The court reversed a judgment that had dismissed an action brought by appellant taxpayers against appellees, a federal agency and its officials, on the grounds that appellants lacked standing to challenge expenditure of federal tax funds for alleged violation of the Establishment and Free Exercise Clauses of U.S. Constitutional Amendment I. 
• The court held that a taxpayer would have standing consistent with U.S. Constitutional art. III to invoke federal judicial power when he alleged that congressional action under the Taxing and Spending Clause was in derogation of those constitutional provisions which operated to restrict the exercise of the taxing and spending power. 
• Under the test announced here, appellants satisfied both nexuses of the test. 
• Appellants' constitutional challenge was made to an exercise by Congress of its power under U.S. Constitutional art. I, § 8, and the challenged program involved a substantial expenditure of federal tax funds. 
• Furthermore, appellants alleged that the challenged expenditures violated the Establishment and Free Exercise Clauses. 
• Appellants' complaint contained sufficient allegations to give them standing to invoke a federal court's jurisdiction.

CONCLUSION
The court reversed a judgment dismissing appellant taxpayers' action for the alleged unconstitutional expenditure of federal funds under a federal statute because under a test announced in the decision, appellants' complaint contained sufficient allegations to invoke a federal court's jurisdiction.