Singleton v. Wulff

Brief Fact Summary.

The constitutionality of a Missouri statute that prohibited Medicaid funding of abortions that were not “medically indicated” is questioned. The district court dismissed Plaintiff’s case for lack of standing to bring this claim. The court of appeals reversed and ruled for Plaintiff on the merits. The United States Supreme Court granted certiorari to determine the standing issue.

Synopsis of Rule of Law.

A plaintiff has standing to bring a lawsuit on behalf of a third party’s right when that right is inextricably bound up with the activity the litigant wishes to pursue, and when it is unlikely that the third party can or will sue on his or her own behalf.

Facts.

Singleton (Plaintiff) was a Missouri-licensed physician who, along with another Missouri physician, challenged the constitutionality of a Missouri statute that prohibited Medicaid funding of abortions that were not “medically indicated.” Plaintiff sued Wulff (defendant), the Missouri state official responsible for determining the appropriateness of Medicaid benefits, on behalf of impoverished female clients that depended on Medicaid benefits to fund their abortions. The district court dismissed Plaintiff’s case for lack of standing to bring this claim. The court of appeals reversed, finding that Plaintiff had standing and also ruled for Plaintiff on the merits. The United States Supreme Court granted certiorari to determine the standing issue.

Issue.

Whether the physicians have a sufficiently close relationship with their third party patients, and whether it is unlikely those patients could bring a suit on their own behalf, so as to justify the physicians having standing to challenge the Missouri abortion statute in court.

Held.

Yes. The court of appeals’ ruling is reversed, as only the standing issue was before the court of appeals at the time it rendered its opinion. A plaintiff has standing to bring a lawsuit on behalf of a third party’s right when that right is inextricably bound up with the activity the litigant wishes to pursue, and when it is unlikely that the third party can or will sue on his or her own behalf.

Concurrence.

Stevens, J.
The physicians had standing, but not because of the reasons articulated by the plurality. Instead, standing is appropriate because the physicians had a financial stake in the outcome of the litigation, and they claimed the Missouri statute impacted their own constitutional rights. Both factors are enough to confer standing on the physicians.

Powell, J.
The physicians have standing to challenge the Missouri abortion statute because it inhibits their own constitutional rights. Additionally, the court of appeals should not have considered the physicians’ case on the merits when only the standing issue was before it. Historically, standing has been conferred on physicians to sue on behalf of their patients when the government has expressly interfered with the physician-patient relationship. However, in this case, Missouri’s statute regulating the funding of abortions by Medicaid does not actually interfere with the relationship between the physicians and their patients. The physicians do not actually have a right that is impacted by the statute that justifies giving them standing to challenge the statute in court. The statute merely affects the patients’ right to receive state funding for the procedures.

Discussion.

The physicians have standing to challenge the Missouri statute on behalf of their Medicaid-qualifying clients because of the sufficient presence of two factors. Firstly, the right of these clients to receive abortions is inextricably bound up with the physicians’ suit to require Medicaid to pay for these abortions. Women cannot safely secure abortions without the aid of a physician, and impoverished women cannot receive the aid of physicians unless Medicaid funds the physicians’ services. Thus, the physicians have a sufficiently close relationship with their female clients to satisfy the first prong of establishing standing in court. Secondly, practical concerns mean it is unlikely that the physicians’ female clients would bring such a lawsuit on their own behalf. Many women wish to protect their privacy by not engaging in a lawsuit to assert their right to an abortion. Also, the nature of a pregnancy lasting for only nine months makes it nearly impossible for women to apply for Medicaid benefits, have the application denied, and then successfully bring a lawsuit challenging the denied application before the time for legally securing an abortion has passed. Thus, it makes sense to allow physicians to represent their clients in asserting this right so that the case or controversy does not become moot before it can be decided. Thus the second prong required for establishing standing in court is satisfied.