Frothingham v. Mellon

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In Frothingham v. Mellon, 262 U.S. 447 (1923), the US Supreme Court held that a taxpayer did not have standing to sue the federal government in order to prevent particular expenditure where her only loss was an anticipated increase in taxes. The Court reasoned that the relationship between the expenditure and the anticipated tax increase was too complex and uncertain to properly determine the effect of one upon the other. Further, the Court reasoned that in accordance with the doctrine of the separation of powers, it would be improper for it to review governmental expenditure in the manner sought.

A narrow exception to the above-mentioned standing rule was established in Flast v. Cohen, 392 U.S. 83 (1968), for Establishment Clause cases.