| Litigants: | Massachusetts v. Mellon |
| Arguedatea: | May 3 |
| Arguedateb: | 4 |
| Argueyear: | 1923 |
| Decidedate: | June 4 |
| Decideyear: | 1923 |
| Fullname: | Commonwealth of Massachusetts v. Mellon, Secretary of the Treasury, et al.; Frothingham v. Mellon, Secretary of the Treasury, et al. |
| Usvol: | 262 |
| Uspage: | 447 |
| Parallelcitations: | 43 S. Ct. 597; 67 L. Ed. 1078 |
| Prior: | Frothingham v. Mellon, 288 F. 252 (D.C. Cir. 1923) |
| Majority: | Sutherland |
| Joinmajority: | unanimous |
| Overruled: | Flast v. Cohen (1968) (in part) |
Massachusetts v. Mellon, 262 U.S. 447 (1923), was a United States Supreme Court case in which the Court rejected the concept of taxpayer standing.[1] The case was consolidated with Frothingham v. Mellon. The plaintiffs in the cases, Frothingham and Massachusetts, sought to prevent certain federal government expenditures which they considered to violate the Tenth Amendment. The court rejected the suits on the basis that neither plaintiff suffered particularized harm, writing:
This case is considered the beginning of the doctrine of standing. Prior to it the doctrine was that all persons had a right to pursue a private prosecution of a public right.[2]
The Warren Court would later carve out an exception to this rule in Flast v. Cohen, but later cases have confirmed that Flast is an exceedingly limited exception to Frothingham general rule (see Valley Forge Christian College v. Americans United for Separation of Church and State and Hein v. Freedom From Religion Foundation).