Massachusetts v. Mellon; Frothingham v. Mellon

Brief Fact Summary.

It is asserted that the appropriations constitute an effective means of inducing the States to yield a portion of their sovereign rights. In the Massachusetts case, the plaintiff asserted that his rights and powers as a sovereign State and the rights of its citizens have been invaded and usurped by the expenditures and acts. In the Frothingham case, plaintiff alleges that the effect of the statute will be to take her property, under the guise of taxation, without due process of law.

Synopsis of Rule of Law.

The judicial power of the Court extends to “controversies between a State and citizens of another State” and the Court has original jurisdiction in all cases in which a State shall be party. The Court gets this jurisdiction not merely because a State is a party, but only  where it is a party to a proceeding of judicial cognizance.

Facts.

The two cases challenge the constitutionality of the Maternity Act, which provides appropriations to States that agree to comply with its provisions for the purpose of cooperating with the States to reduce maternal and infant mortality and to protect the health of mothers and infants. The Act created a bureau to administer the act in cooperation with state agencies, required to make reports on expenditures. It is asserted that that the appropriations under the Act are for purposes not national, but local to the States. The state of Massachusetts and an individual in the same state argued that the Act abridges the state and individual rights in violation of the Constitution.

Issue.

Does the Maternity Act – that provides appropriations to States that agree to comply with its provisions for the purpose of cooperating with the States to reduce maternal and infant mortality and to protect the health of mothers and infants – violate the Constitution?

Held.

The Court disposed of the cases for lack of jurisdiction without considering the merits of the constitutional questions, stating that the State of Massachusetts presented no justiciable controversy either in its own behalf or as the representative of its citizens and that the appellant in the second case had no interest the subject matter or any injury inflicted as will enable her to sue.

Discussion.

While the State, under some circumstances, may sue in that capacity for the protection of its citizens, it is not the State’s duty or power to enforce their rights in respect of their relations with the Federal Government. In such instances, it is the United States or Congress, not the State, which represents citizens as parent of the people, when such representations become appropriate. Moreover, despite the  plaintiff’s contention that the appropriations will increase the burden of future taxation is without a merit. The right of a taxpayer to enjoin the execution of a federal appropriation act, on the ground that it is invalid and will result in taxation for illegal purposes, has never been passed by the Court. His interest in the moneys of the Treasury is shared with millions of others and is thus comparatively minute and indeterminable. The effect upon future taxation is so remote and uncertain. Therefore, there is no basis for an appeal by the plaintiffs.