End date 1998 | ||
Full case name Federal Election Commission v. James E. Akins, Richard Curtiss, Paul Findley, Robert J. Hanks, Andrew Killgore, and Orin Parker Citations 524 U.S. 11 (more)
118 S. Ct. 1777; 141 L. Ed. 2d 10; 1998 U.S. LEXIS 3567; 66 U.S.L.W. 4426; 98 Cal. Daily Op. Service 4092; 98 Daily Journal DAR 5637; 98 Colo. J. C.A.R. 2743; 11 Fla. L. Weekly Fed. S 581 Prior history On writ of certiorari to the United States Court of Appeals for the District of Columbia Circuit Majority Breyer, joined by Rehnquist, Stevens, Kennedy, Souter, Ginsburg Dissent Scalia, joined by O'Connor, Thomas Ruling court Supreme Court of the United States Similar Lujan v Defenders of Wildlife, Spokeo - Inc v Robins, Clinton v City of New York, Massachusetts v Environm, Buckley v Valeo | ||
Federal Election Commission v. Akins, 524 U.S. 11 (1998)[1], was a United States Supreme Court case deciding that an individual could sue for a violation of a federal law pursuant to a statute enacted by the U.S. Congress which created a general right to access certain information.
Contents
Facts
The plaintiffs were registered voters who had asked the defendant Federal Elections Commission ("FEC") to determine that an organization called the American Israel Public Affairs Committee ("AIPAC") was a "political committee" subject to certain regulations and reporting requirements under the Federal Election Campaign Act, because AIPAC had crossed certain spending thresholds. The FEC determined that AIPAC had indeed crossed those thresholds, but still did not require it to make the required reports because the organization was issue-oriented, not campaign-related. The plaintiffs sought review in the District Court, which granted summary judgment for the FEC; this ruling was affirmed by a panel of the Court of Appeals, but the Court of Appeals en banc reversed. The government sought certiorari, and challenged the plaintiff's standing on the grounds that the plaintiffs had suffered no 'injury in fact'; that if the plaintiffs had any injury it was not fairly traceable to the FEC decision; and that a decision in favor of the plaintiffs would not redress their injury.
Issue
Did the plaintiffs suffer an injury in fact sufficient to establish standing?
Opinion of the Court
The Court, in an opinion by Justice Breyer, held that Congress has, by statute, allowed "any party aggrieved by an order of the Commission" to file a suit, which is a broad grant; not getting the requested information is an "injury in fact" just like the denial of any other information which is statutorily required to be provided to citizens by the government. The grievance is a "generalized grievance," but the harm is concrete enough to overcome this, and the harm is fairly traceable to the FEC – even though the FEC may find other grounds not to make AIPAC provide the info. ("[W]here a harm is concrete, though widely shared, the Court has found 'injury in fact.'" Federal Election Commission v. Akins 524 U.S. 11, 24 (1998))
The Court distinguished this case from lawsuits where an individual seeks relief based on mere taxpayer standing - an insufficient ground for standing to sue. It instead employed a "zone of interests test," asking whether the injury asserted fell into the zone of interests protected by the statute.
The case was remanded to the FEC to review its definition of 'members.' The Court noted that the FEC was producing new guidelines regarding this issue, which would address it and not require a new legal precedent. The plaintiffs were bitterly disappointed by the decision not to intervene, as the effort to have AIPAC legally declared a political action committee was a higher priority than the (successful) effort to show standing to have filed this lawsuit in the first place.
Dissent
Justice Scalia wrote a dissenting opinion asserting that the fact the statute differentiated between 'any person' (in defining the class of persons who could file a complaint with the FEC over a violation) and 'any party aggrieved' (in defining the class of persons who could bring suit in federal court over the FEC's decision on the complaint) demonstrated the limiting force of the latter provision—anyone could file a complaint with the FEC if they believed a violation had occurred, but only parties who had actually been aggrieved (suffered a particularized injury) as a result of the FEC's decision on the complaint could sue.