Federal Election Commission v. Akins
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| Federal Election Commission v. Akins | |||||||||||
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 Supreme Court of the United States |
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| Argued January 14, 1998 Decided June 1, 1998 |
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| Holding | |||||||||||
| The Court held that an individual could sue for a violation of a federal law pursuant to a statute enacted by the U.S. Congress which created a general right to access certain information. | |||||||||||
| Court membership | |||||||||||
| Chief Justice: William Rehnquist Associate Justices: John Paul Stevens, Sandra Day O'Connor, Antonin Scalia, Anthony Kennedy, David Souter, Clarence Thomas, Ruth Bader Ginsburg, Stephen Breyer |
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| Case opinions | |||||||||||
| Majority by: Breyer Joined by: Rehnquist, Stevens, Kennedy, Souter, Ginsburg Dissent by: Scalia Joined by: O'Connor, Thomas |
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| Laws applied | |||||||||||
| U.S. Const. | |||||||||||
Federal Election Commission v. Akins, 524 U.S. 11 (1998), was a United States Supreme Court case deciding that an individual could sue for a violation of a federal law pursuant to a statute enacted by the U.S. Congress which created a general right to access certain information.
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[edit] Facts
The plaintiffs were registered voters who had asked the defendant Federal Elections Commission ("FEC") to determine that an organization called the American Israel Public Affairs Committee ("AIPAC") was a "political committee" subject to certain regulations and reporting requirements under the Federal Election Campaign Act, because AIPAC had crossed certain spending thresholds. The FEC determined that AIPAC had indeed crossed those thresholds, but still did not require it to make the required reports because the organization was issue-oriented, not campaign-related. The plaintiffs sought review in the District Court, which granted summary judgment for the FEC; this ruling was affirmed by a panel of the Court of Appeals, but the Court of Appeals en banc reversed. The government sought certiorari, and challenged the plaintiff's standing on the grounds that the plaintiffs had suffered no 'injury in fact'; that if the plaintiffs had any injury it was not fairly traceable to the FEC decision; and that a decision in favor of the plaintiffs would not redress their injury.
[edit] Issue
Did the plaintiffs have standing to challenge the FEC ruling?
[edit] Opinion of the Court
The Court, in an opinion by Justice Breyer, held that Congress has, by statute, allowed 'any party aggrieved by an order of the Commission' to file a suit, which is a broad grant; not getting the requested information is an 'injury in fact' just like the denial of any other information which is statutorily required to be provided to citizens by the government. The grievance is a 'generalized grievance,' but the harm is concrete enough to overcome this, and the harm is fairly traceable to the FEC – even though the FEC may find other grounds not to make AIPAC provide the info.
The Court distinguished this case from lawsuits where an individual seeks relief based on mere taxpayer standing - an insufficient ground for standing to sue. It instead employed a "zone of interests test," asking whether the injury asserted fell into the zone of interests protected by the statute.
The case was remanded to the FEC to review its definition of 'members.'
[edit] Dissent
Justice Scalia wrote a dissenting opinion asserting that the fact the statute differentiated between 'any person' (in defining the class of persons who could file a complaint with the FEC over a violation) and 'any party aggrieved' (in defining the class of persons who could bring suit in federal court over the FEC's decision on the complaint) demonstrated the limiting force of the latter provision -- anyone could file a complaint with the FEC if they believed a violation had occurred, but only parties who had actually been aggrieved (suffered a particularized injury) as a result of the FEC's decision on the complaint could sue.
