Frothingham v. Mellon

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In Frothingham v. Mellon, 262 U.S. 447 (1923), this Court held that Article III and the separation of powers generally standing to sue based merely on plaintiff's status as a taxpayer. An narrow and liberal exception to this rule was established in Flast v. Cohen, 392 U.S. 83 (1968), for Establishment Clause cases.