VALLEY FORGE CHRISTIAN COLLEGE V. AMERICANS UNITED FOR SEPARATION OF CHURCH AND STATE, INC. 454 U.S. 464 (1982) CASE BRIEF

VALLEY FORGE CHRISTIAN COLLEGE V. AMERICANS UNITED FOR SEPARATION OF CHURCH AND STATE, INC.

454 U.S. 464 (1982)

NATURE OF THE CASE: This was a dispute over the government's gift of land to a Christian college.

FACTS: Pursuant to its authority under the Property Clause, Congress enacted the Federal Property and Administrative Services Act of 1949 to provide an economical and efficient system for the disposal of surplus Federal Government property. Property formerly used as a military hospital was declared to be 'surplus property' under the Act and was conveyed by the Department of HEW to petitioner church-related college. The appraised value of the property, $577,500, was discounted by the Secretary of HEW's computation of a 100% public benefit allowance, thus permitting petitioner to acquire the property without making any financial payment. In August 1976, the government gave Valley Forge Christian College (D) 77 acres of land worth $577,500 for no payment of money. The deed that conveyed the land required D to use the property for 30 years solely for the educational purposes described in D's application for the property. D is a nonprofit educational institution operating under the supervision of a religious order known as the Assemblies of God. Americans (P) sued to challenge the conveyance under the Establishment Clause. P sought a declaration that the conveyance was null and void. D moved for a summary judgment under standing to sue. The District Court found that P failed to allege that they have suffered any actual or concrete injury beyond the generalized grievance common to all taxpayers. Respondents appealed to the Court of Appeals for the Third Circuit, which reversed the judgment of the District Court by a divided vote. All members of the court agreed that respondents lacked standing as taxpayers to challenge the conveyance under Flast since that case extended standing to taxpayers qua taxpayers only to challenge congressional exercises of the power to tax and spend conferred by Art. I, 8, of the Constitution, and this conveyance was authorized by legislation enacted under the authority of the Property Clause, Art. IV, 3, cl. 2. Notwithstanding this significant factual difference from Flast, the majority of the Court of Appeals found that respondents had standing merely as 'citizens,' claiming '`injury in fact' to their shared individuated right to a government that `shall make no law respecting the establishment of religion.'' The Supreme Court granted certiorari.

ISSUE:

RULE OF LAW:

HOLDING AND DECISION:

LEGAL ANALYSIS:

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