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Threshold Requirements: Standing, Case or Controversy & Ripeness

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  • 0:06 Standing Doctrine
  • 1:52 Case and Controversy Doctrine
  • 3:53 Ripeness Doctrine
  • 5:04 Lesson Summary
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Lesson Transcript
Instructor: Kat Kadian-Baumeyer

Kat has a Master of Science in Organizational Leadership and Management and teaches Business courses.

Threshold requirements are conditions that a plaintiff must meet in order to take another person or entity to court. There are threshold requirements for standing, case and controversy and ripeness. With all three, the court will require answers to specific questions to determine whether legal action can be taken against a party.

Standing Doctrine

Standing threshold questions whether the party bringing on legal action is actually a real party to the case. In other words, the suing party must have suffered an injury as a result of another's action that is personal to the plaintiff.

To determine this, the plaintiff must prove injury in fact. This means the plaintiff suffered specifically injuries stated or foresees an imminent injury as a result of someone's actions. The injury cannot be shared by a vast majority of people.

A case analysis will help. In Frothingham v. Mellon (1923), a taxpayer insisted that allocating taxes, in part, collected to fund the Maternity Act to assist unborn child and maternal mortality rates, was in violation of her Fourteenth Amendment right against the seizure of property without due process.

Frothingham contended that using tax dollars to fund what she believed was a corrupt system would increase her yearly taxes. This tax hike, in her mind, was akin to taking her money, or property, without due process. Unfortunately, the court did not agree with her allegation and ruled that she did not have standing to bring on a lawsuit against the Department of Treasury.

The ruling was based on the fact that Frothingham was not solely injured by the collection of taxes. She shared that burden with millions of other citizens. Further, there were too many unforeseen circumstances to determine the effect the Maternity Act and the tax hike would have on one individual within society. The court held that this case did not meet the threshold for standing. In other words, the case was without merit. Another question of whether a lawsuit has merit is in the facts and details of the case itself.

Case and Controversy Doctrine

There are situations where a plaintiff believes that they have been wronged in the past, but the case in the present is moot, meaning it no longer has merit. Case and controversy limitations refer to the power the court has to determine whether to hear a case based on whether the injured party has a justifiable case against the defendant. In layman's terms, the court must find a plaintiff-defendant relationship between the parties. This is important because some lawsuits have multiple plaintiffs and defendants.

In Arizonans for Official English Language v. Arizona (1997), plaintiff Maria Kelly F. Yniguez named the State of Arizona, Governor, Attorney General and Director of the Department of Administration as defendants in a lawsuit alleging a violation of her First Amendment right to free speech. Under Arizona State Constitution, Article XXVIII, English would be the official language and the only language used in the state.

Yniguez was a state employee and a native Spanish speaker. In the course of her employment, she often interloped between the two languages. Since our interest is solely on the plaintiff-defendant relationship, we will focus only on the parties and not the outcome of this complex case.

Based on immunity righted by the Eleventh Amendment, the State was dismissed from the case. The State Attorney General was also dismissed, because it was not within his power to enforce the state amendment in question. Because the Director of the Department of Administration did not exercise any action against Yniguez for speaking Spanish during her employment, she was also dismissed from the case.

The important point being, once the lawsuit was evaluated by the court, it was determined that although several parties were named as defendants, only the Governor, for his part in approving the amendment, could be named as a defendant. Finally, a legal dispute must be substantial enough or fully developed to be considered a case worth trying.

Ripeness Doctrine

Let's take a step back to the standing doctrine. We learned that a case must have merit and the plaintiff must have suffered a real injury as a result of the defendant. Ripeness works in a similar way. Ripeness requires that a case have significant enough controversy to warrant being heard before the court.

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