Massachusetts v. Mellon case brief

Massachusetts v. Mellon case brief summary
262 U.S. 447 (1923)

CASE SYNOPSIS

Appellant state and appellant taxpayer challenged earlier Unites States Supreme Court and the Court of Appeals of the District of Columbia decisions which refused to enjoin enforcement of the Act of November 23, 1921 (Act), ch. 135, 42 Stat. 224, after appellants argued the Act was unconstitutional.

CASE FACTS
Appellant state and appellant taxpayer challenged in actions consolidated on appeal earlier court decisions denying their claims to enjoin the Act of November 23, 1921 (Act), ch. 135, 42 Stat. 224, which allegedly involved misappropriation of funds. Appellant state argued the Act was unconstitutional because it invaded areas of local concern in violation of U.S. Constitutional Amendment X. Appellant taxpayer argued that misappropriations under the Act would increase future tax burdens thus taking her property without due process of law.

DISCUSSION

• The court on appeal affirmed the earlier decisions without considering the constitutional merits because appellate jurisdiction was improper. 
• The court held that appellant state presented no justiciable controversy on behalf of itself or its citizens and that appellant taxpayer lacked standing to challenge the Act because she had no subject-matter interest based simply on her taxpayer status and was not injured or threatened to be injured by the Act.

CONCLUSION
Earlier court decisions refusing to enjoin the Maternity Act were affirmed for want of jurisdiction. The court held that appellant state presented no justiciable controversy on either its own behalf or its citizens' behalf and that appellant taxpayer had no interest in the action nor any actual or threatened injury.

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