Singleton v. Wulff

Brief Fact Summary. Two Missouri physicians sued the state, charging that Missouri’s statute prohibiting Medicaid payments for abortions which are not “medically indicated” unconstitutionally interferes with the decision to terminate a pregnancy.

Synopsis of Rule of Law. The rule prohibiting third-party standing should not apply when the relationship of the litigant and the one whose rights he asserts is significantly close and where there is some obstacle to the first party bringing a suit on his own.

Facts. Two Missouri physicians sued the state, showing that they had provided abortions to Medicaid-eligible patients. The state had denied payment for these services on statutory grounds. The physicians stated that they would continue to perform such procedures and stood to be denied payments in the future.

Issue. Do the physicians have standing to bring the suit when the immediately affected are indigent women seeking abortions?

Held. Yes. Court of appeals ruling affirmed.
Two standing questions were presented: (i) whether plaintiff sustained injury in fact and (ii) whether they are the proper individuals to assert the constitutional right in question. The first question is easily answered. Here, the physicians have been denied compensation and stand to be denied further compensation.
As to the second question, the general rule of prohibiting third-party standing only applies if the relationship between the litigant and the party directly affected is such that the litigant does not effectively serve as a proponent of the affected party and if there is some impediment to the affected party bringing suit himself. Here, the litigant was deemed to effectively serve as a proponent.

Discussion. The Supreme Court of the United States (Supreme Court) does not say that there must be an absolute obstacle to the directly affected party bringing suit, only that there is some genuine impediment (e.g., protecting the privacy of her decision to terminate a pregnancy, the imminent mootness of her claim, etc.).