Clinton v. City of New York

In Clinton v. City of New York, 524 U.S. 417 (1998), the United States Supreme Court considered whether the term "individual" in a section of the former Line Item Veto Act included corporations: "'Any member of Congress or any individual adversely affected' by the Act" may bring an action contesting the constitutionality of the Act. Id. at 428 (quoting former 2 U.S.C. 692(a)(1)). The Court determined "that in the context of the entire section Congress undoubtedly intended the word 'individual' to be construed as synonymous with the word 'person,'" a word that includes "corporations." Id. at 428-29 & n.13. The Court explained that the purpose of the section was to authorize "prompt and authoritative judicial determination of the constitutionality of the Act" and reasoned "there is no plausible reason why Congress would have intended to provide for such special treatment of actions filed by natural persons and . . . not corporate persons." Id. at 429. Thus, the Court interpreted the term "individual" from its context within the Line Item Veto Act.