Allen v. Wright
In Allen v. Wright, 468 U.S. 737, 104 S.Ct. 3315, 3326-27, 82 L.Ed.2d 556 (1984), the Court found that an injury to parents' abilities to have their community schools desegregated was not fairly traceable to IRS tax exemptions to racially discriminatory schools.
The Court reasoned that the chain of causation depended on the uncertain responses of numerous third parties to the IRS action. The diminished ability to receive a desegregated education would be linked to the tax exemption only if (1) there were a sufficient number of private schools in the community for withdrawal of the exemption to make a difference in integration, (2) withdrawal of the exemption would cause a private school to change its policies, and (3) a given parent would transfer a child to public school if discriminatory policies were changed. Moreover, these "independent decisions may not collectively have a significant effect on the ability of public-school students to receive a desegregated education." 104 S.Ct. at 3329.
In Allen the Court had upheld the black parents' standing on the theory that "the sole injury respondents claim is the denigration they suffer as black parents and schoolchildren when their government graces with tax-exempt status educational institutions in their communities that treat members of their race as persons of lesser worth." 468 U.S. at 749, 104 S.Ct. at 3323 (quoting Wright v. Regan, 656 F.2d 820, 827 (D.C.Cir.1981)).
The Supreme Court reversed, stating as follows:
There can be no doubt that this sort of noneconomic injury is one of the most serious consequences of discriminatory government action and is sufficient in some circumstances to support standing. See Heckler v. Mathews, 465 U.S. 728, 739-740, 104 S.Ct. 1387, 1395, 79 L.Ed.2d 646 (1984). Our cases make clear, however, that such injury accords a basis for standing only to "those persons who are personally denied equal treatment" by the challenged discriminatory conduct, ibid. Allen, 468 U.S. at 755, 104 S.Ct. at 3326.