simon
eastern
ky
welfare
rights
argued
december
decided
june
together
eastern
kentucky
welfare
rights
organization
et
al
simon
secretary
treasury
et
also
certiorari
respondents
hereinafter
respondents
several
individuals
organizations
representing
individuals
brought
class
action
district
behalf
persons
unable
afford
hospital
services
secretary
treasury
commissioner
internal
revenue
claimed
revenue
ruling
announced
internal
revenue
service
policy
extending
favorable
tax
treatment
internal
revenue
code
code
hospitals
serve
indigents
extent
hospitals
financial
ability
encouraged
hospitals
deny
services
indigents
invalid
erroneous
interpretation
code
issued
violation
administrative
procedure
act
apa
complaint
described
instances
individual
respondents
refused
treatment
indigency
hospitals
enjoying
favorable
tax
treatment
policy
announced
challenged
revenue
ruling
alleged
receiving
substantial
contributions
result
treatment
district
overruled
motion
dismiss
petitioners
hereinafter
petitioners
included
challenge
respondents
standing
summary
judgment
held
revenue
ruling
void
contrary
code
appeals
also
found
standing
respondents
upheld
revenue
ruling
held
district
granted
petitioners
motion
dismiss
respondents
failed
establish
standing
bring
suit
pp
plaintiff
standing
challenged
relevant
inquiry
whether
assuming
justiciability
claim
plaintiff
shown
injury
likely
redressed
favorable
decision
unless
showing
made
federal
exercise
power
consistent
case
controversy
limitation
art
iii
constitution
pp
respondent
organizations
alleged
injury
qua
organizations
establish
standing
simply
basis
dedicated
promoting
access
poor
health
services
organization
abstract
concern
subject
affected
adjudication
substitute
concrete
injury
required
art
iii
sierra
club
morton
pp
allegations
individual
respondents
members
respondent
organizations
denied
hospital
services
indigency
establish
case
controversy
suit
brought
hospital
treasury
officials
art
iii
case
controversy
limitation
requires
federal
act
redress
injury
fairly
traced
challenged
action
defendant
solely
third
party
pp
though
petitioners
alleged
adoption
revenue
ruling
encouraged
hospitals
deny
services
indigents
purely
speculative
whether
alleged
denials
service
ascribable
petitioners
encouragement
resulted
hospitals
decisions
apart
tax
considerations
whether
exercise
district
remedial
powers
make
services
available
respondents
respondents
allegation
hospitals
denied
service
receive
substantial
contributions
without
establish
hospitals
dependent
upon
contributions
thus
appears
respondents
relied
little
remote
possibility
unsubstantiated
allegations
fact
situation
might
better
petitioners
acted
otherwise
might
improve
district
afford
relief
warth
seldin
consequently
respondents
failed
carry
burden
showing
injury
consequence
petitioners
action
prospective
relief
remove
harm
warth
seldin
supra
linda
richard
followed
pp
powell
delivered
opinion
burger
stewart
white
blackmun
rehnquist
joined
stewart
filed
concurring
statement
post
brennan
filed
opinion
concurring
judgment
marshall
joined
post
stevens
took
part
consideration
decision
cases
stuart
smith
argued
cause
petitioners
respondents
brief
solicitor
general
bork
assistant
attorney
general
crampton
ernest
brown
leonard
henzke
robert
bernstein
marilyn
rose
argued
cause
respondents
petitioners
briefs
joseph
fn
briefs
amici
curiae
urging
reversal
filed
stanton
price
american
public
health
stanley
christopher
russell
jacobson
jackson
county
mo
robert
bromberg
filed
brief
american
hospital
assn
amicus
curiae
urging
affirmance
justice
powell
delivered
opinion
several
indigents
organizations
composed
indigents
brought
suit
secretary
treasury
commissioner
internal
revenue
asserted
internal
revenue
service
irs
violated
internal
revenue
code
code
administrative
procedure
act
apa
issuing
revenue
ruling
allowing
favorable
tax
treatment
nonprofit
hospital
offered
services
indigents
conclude
plaintiffs
lack
standing
bring
suit
code
original
version
subsequent
amendment
accords
advantageous
treatment
several
types
nonprofit
corporations
including
exemption
income
taxation
deductibility
benefactors
amounts
donations
nonprofit
hospitals
never
received
benefits
favored
general
category
individual
nonprofit
hospital
able
claim
qualify
corporation
organized
operated
exclusively
charitable
purposes
within
meaning
code
code
define
term
charitable
status
nonprofit
hospital
determined
basis
irs
recognition
need
nonprofit
hospitals
guidelines
qualification
charitable
corporations
irs
issued
revenue
ruling
ruling
established
position
irs
term
charitable
legal
sense
used
section
code
contemplates
implied
public
trust
constituted
public
benefit
addition
ruling
set
four
general
requirements
hospital
meet
among
things
considered
charitable
organization
irs
one
requirements
important
reads
follows
must
operated
extent
financial
ability
able
pay
services
rendered
exclusively
able
expected
pay
normal
hospitals
charge
able
pay
services
rendered
order
meet
operating
expenses
institution
without
denying
medical
care
treatment
others
unable
pay
fact
charity
record
relatively
low
conclusive
hospital
operated
charitable
purposes
full
extent
financial
ability
may
furnish
services
reduced
rates
cost
thereby
render
charity
manner
may
also
set
aside
earnings
uses
improvements
additions
hospital
facilities
must
however
refuse
accept
patients
need
hospital
care
pay
services
furthermore
operates
expectation
full
payment
renders
services
dispense
charity
merely
patients
fail
pay
services
rendered
hospital
operates
full
time
emergency
room
one
requiring
emergency
care
denied
treatment
hospital
otherwise
ordinarily
limits
admissions
pay
cost
hospitalization
either
private
health
insurance
aid
public
programs
medicare
patients
meet
financial
requirements
admission
ordinarily
referred
another
hospital
community
serve
indigent
patients
ii
issuance
revenue
ruling
led
filing
suit
july
district
district
columbia
group
organizations
individuals
plaintiff
organizations
described
unincorporated
association
several
nonprofit
corporations
included
persons
among
members
represented
interests
persons
obtaining
hospital
care
services
individual
plaintiffs
described
subsisting
poverty
income
levels
established
federal
government
suffering
medical
conditions
requiring
hospital
services
organizations
sued
behalf
members
individual
sued
behalf
representative
persons
similarly
situated
individuals
described
occasion
member
family
disadvantaged
seeking
needed
hospital
services
indigency
involved
refusal
hospital
admit
person
inability
pay
deposit
advance
fee
even
though
instances
person
enrolled
medicare
program
least
one
plaintiff
denied
treatment
inability
pay
immediately
another
treated
emergency
room
billed
threatened
suit
although
indigency
known
time
treatment
according
complaint
hospitals
involved
incidents
determined
secretary
commissioner
charitable
corporation
received
substantial
private
contributions
secretary
commissioner
defendants
complaint
alleged
extending
tax
benefits
hospitals
despite
refusals
fully
serve
indigent
defendants
encouraging
hospitals
deny
services
individual
plaintiffs
members
clients
plaintiff
organizations
persons
alleged
suffering
injury
opportunity
ability
receive
hospital
services
nonprofit
hospitals
receive
benefits
charitable
organizations
code
also
alleged
among
intended
beneficiaries
code
sections
grant
favorable
tax
treatment
charitable
organizations
plaintiffs
made
two
principal
claims
first
issuing
revenue
ruling
defendants
violated
code
granting
treatment
nonprofit
hospitals
refused
fully
serve
indigents
defendants
continued
violation
theory
legislative
history
code
regulations
irs
judicial
precedent
established
term
charitable
code
mean
relief
poor
challenged
ruling
current
practice
irs
departed
interpretation
plaintiffs
second
claim
issuance
revenue
ruling
without
public
hearing
opportunity
submission
views
violated
rulemaking
procedures
apa
theory
claim
ruling
considered
substantive
rule
opposed
interpretative
type
rule
exempted
requirements
plaintiffs
sought
various
forms
declaratory
injunctive
relief
motion
dismiss
defendants
challenged
plaintiffs
standing
suggested
nonjusticiability
subject
matter
suit
asserted
event
action
barred
act
tax
limitation
declaratory
judgment
act
doctrine
sovereign
immunity
district
denied
motion
without
opinion
subsequent
summary
judgment
considered
rejected
defendants
arguments
reaching
merits
held
revenue
ruling
improperly
promulgated
without
effect
insofar
permitted
nonprofit
hospitals
qualify
tax
treatment
charities
without
offering
special
financial
consideration
persons
unable
pay
supp
appeals
district
columbia
circuit
reversed
app
agreed
district
rejection
defendants
jurisdictional
contentions
held
merits
revenue
ruling
founded
upon
permissible
definition
charitable
contrary
congressional
intent
code
plaintiffs
apa
claim
district
reached
appeals
held
revenue
ruling
interpretative
ruling
thus
exempt
apa
rulemaking
requirements
plaintiffs
sought
writ
certiorari
review
appeals
judgment
merits
defendants
filed
seeking
review
decision
jurisdictional
issues
plaintiffs
petition
granted
granted
petitions
consolidated
since
deal
defendants
contentions
first
find
unnecessary
reach
issues
raised
plaintiffs
shall
refer
defendants
petitioners
plaintiffs
respondents
iii
petitioners
argued
policy
irs
tax
tax
certain
individuals
organizations
whether
embodied
revenue
ruling
otherwise
developed
challenged
third
parties
whose
tax
liabilities
affected
theory
entire
history
country
revenue
system
including
limited
evolution
code
manifests
consistent
congressional
intent
vest
exclusive
authority
administration
tax
laws
secretary
duly
authorized
delegates
subject
oversight
appropriate
committees
congress
argued
allowing
suits
questioning
tax
treatment
accorded
taxpayers
transfer
determination
general
revenue
policy
away
congress
entrusted
vest
federal
courts
addition
petitioners
analogize
discretion
vested
irs
respect
administration
tax
laws
discretion
public
prosecutor
prosecute
thus
invoke
settled
doctrine
exercise
prosecutorial
discretion
challenged
one
neither
prosecuted
threatened
prosecution
see
linda
richard
petitioners
also
renew
jurisdictional
contentions
action
barred
act
declaratory
judgment
act
doctrine
sovereign
immunity
reach
either
question
whether
third
party
ever
may
challenge
irs
treatment
another
question
whether
statutory
immunity
bar
suit
conclude
district
granted
petitioners
motion
dismiss
ground
respondents
complaint
failed
establish
standing
sue
iv
principle
fundamental
judiciary
proper
role
system
government
constitutional
limitation
jurisdiction
actual
cases
controversies
see
flast
cohen
concept
standing
part
limitation
unlike
associated
doctrines
example
restrains
federal
courts
deciding
political
questions
standing
focuses
party
seeking
get
complaint
federal
issues
wishes
adjudicated
reiterated
last
term
standing
question
art
iii
aspect
whether
plaintiff
alleged
personal
stake
outcome
controversy
warrant
invocation
jurisdiction
justify
exercise
remedial
powers
behalf
warth
seldin
emphasis
original
sum
plaintiff
standing
brought
issue
relevant
inquiry
whether
assuming
justiciability
claim
plaintiff
shown
injury
likely
redressed
favorable
decision
absent
showing
exercise
power
federal
gratuitous
thus
inconsistent
art
iii
limitation
respondents
brought
action
apa
gives
right
judicial
review
person
adversely
affected
aggrieved
agency
action
within
meaning
relevant
statute
data
processing
service
camp
held
constitutional
standing
requirement
section
allegations
true
establish
plaintiff
injured
fact
action
sought
reviewed
reduction
threshold
requirement
actual
injury
redressable
represented
substantial
broadening
access
federal
courts
previously
thought
constitutional
minimum
statute
emphasized
sierra
club
morton
broadening
categories
injury
may
alleged
support
standing
different
matter
abandoning
requirement
party
seeking
review
must
suffered
injury
see
also
richardson
powell
concurring
necessity
plaintiff
seeks
invoke
judicial
power
stand
profit
personal
interest
remains
art
iii
requirement
federal
ignore
requirement
without
overstepping
assigned
role
system
adjudicating
actual
cases
controversies
according
settled
principle
allegations
individual
respondents
respondent
organizations
must
tested
sufficiency
note
outset
five
respondent
organizations
described
dedicated
promoting
access
poor
health
services
establish
standing
simply
basis
goal
decisions
make
clear
organization
abstract
concern
subject
affected
adjudication
substitute
concrete
injury
required
art
iii
sierra
club
morton
supra
see
warth
seldin
supra
insofar
organizations
seek
standing
based
special
interest
health
problems
poor
complaint
must
fail
since
allege
injury
organizations
indeed
context
suit
establish
standing
representatives
members
injured
fact
thus
brought
suit
right
warth
seldin
supra
standing
question
suit
therefore
turns
upon
whether
individual
respondent
established
actual
injury
whether
respondent
organizations
established
actual
injury
indigent
members
obvious
interest
respondents
claim
actual
injury
access
hospital
services
one
sense
course
suffered
injury
interest
complaint
alleges
specific
occasions
individual
respondents
sought
denied
hospital
services
solely
due
indigency
least
cases
clear
needed
treatment
unavailable
practical
matter
anywhere
else
complaint
also
alleges
members
respondent
organizations
need
hospital
services
live
communities
private
hospitals
serve
indigents
thus
assume
purpose
analysis
members
denied
service
injury
hands
hospital
insufficient
establish
case
controversy
context
suit
hospital
defendant
defendants
officials
department
treasury
claims
illegal
action
respondents
desire
courts
adjudicate
charged
officials
although
law
standing
greatly
changed
recent
years
steadfastly
adhered
requirement
least
absence
statute
expressly
conferring
standing
federal
plaintiffs
must
allege
threatened
actual
injury
resulting
putatively
illegal
action
federal
may
assume
jurisdiction
linda
richard
words
case
controversy
limitation
art
iii
still
requires
federal
act
redress
injury
fairly
traced
challenged
action
defendant
injury
results
independent
action
third
party
complaint
alleged
petitioners
adoption
revenue
ruling
encouraged
hospitals
deny
services
indigents
implicit
corollary
allegation
grant
respondents
requested
relief
resulting
requirement
hospitals
serve
indigents
condition
favorable
tax
treatment
discourage
hospitals
denying
services
respondents
follow
allegation
corollary
denial
access
hospital
services
fact
results
petitioners
new
ruling
return
petitioners
previous
policy
result
respondents
receiving
hospital
services
desire
purely
speculative
whether
denials
service
specified
complaint
fairly
traced
petitioners
encouragement
instead
result
decisions
made
hospitals
without
regard
tax
implications
equally
speculative
whether
desired
exercise
remedial
powers
suit
result
availability
respondents
services
far
complaint
sheds
light
plausible
hospitals
respondents
may
apply
service
elect
forgo
favorable
tax
treatment
avoid
undetermined
financial
drain
increase
level
uncompensated
services
true
individual
respondents
alleged
upon
information
belief
hospitals
denied
service
receive
substantial
donations
deductible
donors
allegation
support
inference
hospitals
financially
dependent
upon
favorable
tax
treatment
afforded
charitable
organizations
admit
respondents
required
admission
condition
receipt
treatment
inference
speculative
best
solicitor
general
brief
nationwide
private
philanthropy
accounts
private
hospital
revenues
respondents
introduced
district
statement
congress
official
hospital
association
describing
importance
nonprofit
hospitals
favorable
tax
treatment
receive
charitable
corporations
conflicting
evidence
supports
commonsense
proposition
dependence
upon
special
tax
benefits
may
vary
hospital
hospital
thus
respondents
allegation
certain
hospitals
receive
substantial
charitable
contributions
without
establish
proposition
hospitals
dependent
upon
contributions
prior
decisions
establish
unadorned
speculation
suffice
invoke
federal
judicial
power
linda
richard
mother
illegitimate
child
averred
interpretation
criminal
child
support
statute
applying
fathers
legitimate
children
violated
equal
protection
clause
fourteenth
amendment
sought
injunction
requiring
district
attorney
enforce
statute
father
child
held
mother
lacked
standing
made
showing
failure
secure
support
payments
results
nonenforcement
child
father
statute
prospect
requested
prosecution
fact
result
payment
child
support
instead
jailing
father
speculative
ibid
similarly
last
term
warth
seldin
held
persons
seeking
invalidation
town
restrictive
zoning
ordinance
lacked
standing
failed
show
alleged
injury
inability
obtain
adequate
housing
within
means
fairly
attributable
challenged
ordinance
instead
factors
language
directly
applicable
litigation
noted
plaintiffs
relied
little
remote
possibility
unsubstantiated
allegations
fact
situation
might
better
defendants
acted
otherwise
might
improve
afford
relief
principle
linda
warth
controls
case
stated
warth
principle
indirectness
injury
necessarily
fatal
standing
may
make
substantially
difficult
meet
minimum
requirement
art
iii
establish
fact
asserted
injury
consequence
defendants
actions
prospective
relief
remove
harm
respondents
failed
carry
burden
speculative
inferences
necessary
connect
injury
challenged
actions
petitioners
moreover
complaint
suggests
substantial
likelihood
victory
suit
result
respondents
receiving
hospital
treatment
desire
federal
properly
cognizant
art
iii
limitation
upon
jurisdiction
must
require
respondents
shown
proceeding
merits
accordingly
judgment
appeals
vacated
cause
remanded
district
instructions
dismiss
complaint
ordered
footnotes
cum
bull
cum
bull
substance
ruling
issued
policy
pronouncement
approximately
one
month
earlier
technical
info
rel
descriptions
fit
whole
part
actual
hospitals
whose
tax
status
either
taxpayer
irs
field
office
requested
advice
anonymous
reference
hospitals
revenue
ruling
conformed
irs
practice
deleting
identifying
details
confidential
information
contained
requests
dealt
privately
underlying
fact
situation
used
published
revenue
ruling
see
cum
bull
xxii
reaching
conclusion
irs
cited
law
trusts
premise
promotion
health
charitable
purpose
provided
class
direct
beneficiaries
sufficiently
large
receipt
health
services
said
benefit
community
whole
see
restatement
second
trusts
scott
law
trusts
ed
irs
applied
premise
hospital
concluded
maintaining
open
emergency
room
providing
hospital
care
persons
able
pay
either
directly
insurance
hospital
served
large
enough
class
qualify
charitable
california
welfare
rights
organization
eastern
kentucky
welfare
rights
organization
national
tenants
organization
association
disabled
miners
widows
health
education
advisory
team
one
minor
sued
parents
also
named
plaintiffs
section
xcept
notice
hearing
required
statute
subsection
apply
interpretative
rules
plaintiffs
also
claimed
issuance
revenue
ruling
amounted
abuse
discretion
denied
due
process
law
claims
treated
summarily
courts
plaintiffs
pressed
plaintiffs
requested
judicial
declarations
defendants
violated
code
apa
hospital
charitable
status
required
provision
full
services
persons
unable
pay
medicaid
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