American Moms for Justice: Family Court Reform by Zan Lene

American Moms for Justice: Family Court Reform

Far too many victims of Domestic Violence are being re-victimized in our Family Court systems. It is the all too common practice of doubt that Judges are taught, specifically taught in Judge School, automatic doubt that women (who are the majority of the victims) and innocent children. This is the common practice where non-offending parents are left without protection for their children or for themselves from an abuser. Children all over this country are absolutely falling victim outside of their homes inside of our Family Courts. 

In many Domestic Violence cases with founded evidence of child molestation, this too is also the judicial practice leaving victims with the denial of justice. Upon researching case after case, the findings are that the abusers are not only awarded custody, in far too many cases the non-offending mother loses her children to the worst kind of abuser there is. As an Advocate for American Mothers for Justice, I have discovered what is also happening in cases involving sexual abuse. Prior to a discovery process, I had absolutely no knowledge of cases such as these existing at such an alarming rate. However, many children unfortunately have faced the most unimaginable horror of being forced to survive sexual abuse and sodomy without any protection from their abusers. These are in fact the worst outcome cases in our highly corrupt Family Court systems today. The mothers are living the nightmare also left to fight the Goliath courts to not only seek justice, but to also protect their innocent children.

In far too many cases, it is the abusers who seek custody in retaliation to punish the victims of their abuse. 

Child Protective Services has proven to be one of the most corrupt and fraudulent institutions in the United States. The statistics of foster care deaths and abuse are staggering injustices. Many victims of this Government corruption are that of non-offending parents and children across the Nation at a rapid rate. Children are literally being used as currency and that is not American or Constitutional. There is No Due Process of the law for parents under investigations with non-founded evidence , for this is especially true for the cases where Child Protection Services are being used as a tool for malicious intent, which in reality, the children are placed in potentially dangerous high risk care; whether it be being placed within the care of their abuser, or in the hands of Foster Care. 

Foster Care Statistics are as follows:

54 % earn a high school diploma
2 % earn a Bachelor’s degree or higher
84 % become parents too soon, exposing their children to repeated cycles of neglect and abuse
51 % are unemployed
30 % have no health insurance
25 % experience homelessness
30 % receive public assistance
100 % of children placed in Foster Care are at a high risk of developing Reactive Attachment Disorder (RAD), Depression, Anxiety, Post Traumatic Stress Disorder (PTSD), eating disorders, Attention Deficit Hyperactivity Disorder, as well as other Developmental and Neuro-development issues, and are at potential dangerous risks for suicide. Children placed in Foster Care are 4-11 % at a higher risk for neglect, abuse, molestation, and death. 

The statistics are alarming!

The Title I-V Grants is not “in the best interest “ of our American Children and is not being used for the Restoration of American Families, which instead, children in this country are being legally kidnapped and sold by their own government. Child Abuse is a crime and should be handled by the police so that there is Due Process of the law and just punishment is actually served to actual abusers, by an Open Court with a Jury present where facts presented are actual founded evidence of abuse. 

The proper resources are not being provided, nor is Kincare placement being the option. Instead children are being forced to take dangerous Psychotropic drugs to “adjust” to being placed in Foster Care, when a familiar Kincare environment that is denied to them. Instead the children are ripped from their families, so many never to see them again. Their heritage and roots are being eradicated and left in utter ruins. 

American Children are not for sale!

Please help to Reform our Family Courts and Government Institutions who use the secrecy of closed and gagged court systems in this country in such a corrupt manner that is not just or Constitutional. These American Families have no Constitutional Rights or voices to speak, so that is why I speak to you for them. Reform is the most dire need for the children and families in this country today. We must Restore American Families and preserve the lives and futures of our children.

What do you think of this?

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Left Hook

By Walter Davis

San Diego, California

8 December 2012

Judicial Rights: The Most Important Fight of Our Time

The proud grandparents had come to Italy to witness the birth of their granddaughter. Their sailor-son-in-law was Command Center Supervisor on a Navy admiral’s staff in Naples – Commander Fleet Air Mediterranean. While touring Naples, they visited a fabulous furniture store. Granny got her wish and Pop ordered a living room and dining room set. The ornate carvings on the chairs and tables were very beautiful. They picked a gold fabric to match the beautiful hardwood on their new custom made sofa and chairs. They enjoyed their beautiful new granddaughter. She was joined by a beautiful little sister the following year.

The sofa was delivered in Los Angeles just before the proud new Navy mom and dad arrived about a little more than year later. They were on their way to Japan; to a new assignment in USS MIDWAY CV-41 and new adventure.

They loved their two little girls, born in Germany and Italy during their tour with the Navy’s Sixth Fleet. The oldest, little Adria had been born at 37 weeks, she had been taken by air ambulance to Frankfurt, Germany to be born due to her premature birth. A massive earthquake had hit Italy and her mother went into labor. Katrina, still a tiny infant had been born in Italy 18 months later. Adria, now a toddler, was dancing and running around, so excited to see granny. Dad cautioned her to stop running just before she struck her face on the corner of one of the ornate carvings, blood rushing down her cheek.

The terrified young father administered first aid to the hysterical little cutie and wondered if her face would be permanently scarred. He rushed her to the hospital and explained what happened to the staff. While his girl got stitches in her little face, the real nightmare was about to begin. As a nurse cared for his daughter, the young navigator was escorted to the office of a social worker who asked him how the little toddler got the injury. After explaining again, dad was told by the social worker “That is not how this injury happened!” Surprised, he stated, “Are you saying I am lying?” The social worker replied “Yes, you cut your daughter’s face!”

A hot wave of fear, anger and frustration overcame the young sailor who could not believe what he was hearing. He repeated his story again and the social worker again said he was lying. She took temporary custody of his daughter and left him alone in a room, shocked.

Fortunately, the daughter was returned after a few hours and the couple continued on to Japan shortly afterwards. They were lucky. A conviction of child abuse could have resulted in the end of a promising naval career, loss of a top secret clearance and a beautiful little girl, sold into slavery.

To those unfamiliar with social services, this may sound impossible; sounds like a fluke. If only the latter was true. One only has to visit the website (1) or YouTube Channel (2) of Lawless America to see the corruption of Child Protective Services, Social Services, hospitals and the judicial system.

Lawless America: The Movie will be released in the summer of 2013 (3) and be in major movie theaters. The movie documents widespread corruption within national and local governments. Nearly one thousand people in all 50 states have been interviewed. They are from all income levels, races, backgrounds. ALL American families are at risk. There are a host of Facebook groups and blogs that document corruption among government officials. Some of them can be seen at a centralized blog, Citizens Demanding Justice (4).

The battle, that most do not even realize that they are involved in, is well underway and American families and the families of future generations are in jeopardy.

So how did this get so bad? In the early 70’s Walter Mondale proposed legislation to curb child abuse. Richard Nixon signed the bill into law. Unfortunately, the version that was signed into law provided bonuses to social workers based on how many children were removed from families. Social workers could also be held liable if they made contact with a family that later had abuse reported. So, social workers began to report even the most innocuous actions. Eventually, court officials, attorneys, evaluators and judges realized the huge money making potential involved with taking kids away and selling them to wealthy couples who could not have children. In addition, the foster care system became very profitable with social security funding going to foster care givers and others involved in the process. Bonuses were and are being paid based on the number of children taken away. Sadly, family members were not being given an opportunity to take the kids. This would interrupt the ability of social workers and attorneys to tap into the social security funding (18). Foreign governments, dependent on American aid have been arm twisted into adopting American like drug policies and CPS policies. This problem is international (4).

Foster care parents can make thousands per month per child, especially if they require special attention. Sadly, the evaluators who are making such recommendations in several cases are not credentialed. This is what the California Coalition for Families and Children has discovered as baby selling rings in San Diego and Orange County have been uncovered (7). Conveniently, these foster care children can be dumped on the street when they turn 18. This feeds the vicious cycle where many become pseudo adults, unprepared for life. They turn to drugs as a means to cope and make a living. Arrests and jail time follow. Felony convictions mean they cannot get a job and they become career criminals. They prey on the public and become part of a permanent underclass, keeping law enforcement and attorneys employed while city and county coffers are emptied. The children of these unfortunate people often end up in the CPS system and thus, the cycle perpetuates itself.

Children are being taken away from parents for fabricated charges (5), false positive drug tests (6), falsified CPS reports and corrupt officials running baby selling rings (7) (8). The children are being given to complete strangers. Whether the parents are guilty or not, grandparents, uncles, brothers and other responsible relatives are NOT being given a chance to take custody of the children. This means that family lineages are being destroyed viciously.

In many cases, the foster and or adoptive parents are pedophiles or wealthy families that want to obtain a child, by any means (9).

Lynn states that her son suffered a bump on the head. She took him into the hospital for help and she was accused of beating him. CPS took him AND her older daughter and she may never see them again. She left California and had another child in New York. Pregnant again, she came back to California where she delivered a fourth child. Hospital staff reported she was positive in a drug test. They took her newborn and had her bring in the child born in New York. In all her cases, the children said she had never abused them. Even though drug tests administered in hospitals can yield false positives in 47% of tests (6), Lynn’s third and fourth child were taken and given (sold) to wealthy families who wanted to adopt children. She has never seen them again (9). Statistics have revealed that women of color are 9 times more likely to be tested for drugs in the hospital during a delivery. They also reveal that the propensity of false positives is great (6) and that hospital staff members are allowed to be retested if found to be drug positive while patients are not.

Rarely if ever does one hear the term honest lawyer or, honest politician. Sadly, these individuals have the power to develop laws that affect our families in a profound way. How many realize that SBX 2-11 was passed in 2009? This law gives California judges immunity from criminal prosecution and it is postdated back 20 years (10) (11). For what reason do judges need to be held ABOVE the law that THEY are tasked to uphold?  To be fair, there are many honest lawyers. They are fighting for citizens in subtle ways. Many are afraid of the legal system themselves. The state bar is a tool used against attorneys who do not maintain the status quo (12) (17).

There are MANY judges who are heroes. Judge Deann Salcido is one of those. She has revealed corruption in family court (13). The Honorable Mary E. Bullock, a retired Civil Rights Judge from the Federal Equal Employment Opportunity Commission states that your chances of getting justice in today’s court system are slim to none (14). Even Judge Judy has spoken out about CPS (15).

The reality is that far too many in the legal profession are NOT doing their jobs correctly. The legal system has become a money maker where children are being taken away from decent people and sold. Drug laws are being used as an excuse to destroy people and NEVER allow them to become whole again, no matter what they do.

During a radio show, a young Pennsylvania woman revealed that she had done everything on the CPS list that she was supposed to do to get her_{­­­­­­­} kids back. She was ordered to get STERILIZED. She complied with the order and her newborn was STILL given to an abusive family that burned the baby over 70% of her body (16).

The religious community seems to be lackluster at best in tackling this issue. While MANY champion taking away women’s rights to choose, few seem to be championing loving actions that promote healthy development children after they are born. We see very few heroes like Pastor Wiley of Orange County. He has been a leader in reporting CPS abuses and helping men and women who are victims of the judicial system (19).

Sharon was very secure. Her real estate investments had her family in the million dollar net worth category. She was comfortable and with her husband, they planned to retire and enjoy success. After a leak was discovered in her home, she sued an installation company for faulty work. They had violated environmental standards and put her family at risk. She discovered other families in similar situations and began to help them. The court ordered her to stop talking about her case and when she refused, she was jailed for five days. Today she is having trouble paying her mortgage and is constantly being threatened with jail for revealing corruption within the judicial system. That’s right. Citizens can be ordered NOT to talk about how they have been wronged by the courts and then put in jail if their postings are found on Facebook or blogs (20).

At one time, fire departments would not come to put out fires at homes if a fee had not been paid. The fire “companies” were private and often they would fight each other for the business while homes burned down. In red state Tennessee, such companies still exist today. They will hose down a neighbor’s home to keep them from burning down if YOUR house catches on fire, if you have not paid your fee….while YOUR home burns to the ground. Imagine getting raped or robbed and police checking to see if you paid your fees before helping you. That is the barbaric state of our legal system today. If you cannot pay, you cannot get help and even if you do pay, you still may not get justice. Attorneys are making $225 per hour and up to administer justice. Justice should not be dependent on money. It is barbaric for people to profit on the legal woes of others. A justice system based on profit cannot be sustained in a higher level society.

This system continues to exist because people think that it cannot happen to THEM. Sadly, this can and your chances of ending up in court far outweigh your chances of ending up in the hospital. Your chances of getting justice are not as you may think. This is not Perry Mason.

In America, a citizen is arrested every 38 seconds for drug charges. The prison population is increasing by 10,000 people per month. Americans live in a police state where warehousing people in jail is big business. Rehabilitation is something that happens on television. It is time for a more loving approach to people in American society. The Drug Policy Alliance http://www.drugpolicy.org/ , Law Enforcement Against Prohibition http://www.leap.cc/  and PEW Report http://www.pewstates.org/issues/prison-population-328309 websites are excellent sources of information on this topic. 

In February 2013, thousands of people are planning a mass demonstration in Washington D.C. to protest the injustice system. Lawless America (1) is planning this gathering. Representatives from all 50 states are gathering to present videos and petitions to their congressmen and women. This is fight that involves all Americans. The American people can no longer allow their children to be used as cash commodities. Your support is needed. No one knows this better than the author of this story. You see, he is the sailor mentioned at the beginning of this article.

1.        Lawless America. http://www.LawlessAmerica.com. 4 December 2012. 4 December 2012

2.        Lawless America YouTube Channel.  YouTube Channel. http://www.youtube.com/user/lawlessamerica. 4 December 2012. 4 December 2012.

3.        Lawless America: The Movie Trailer http://www.youtube.com/watch?v=7TuiYsY_SIA. 4 December 2012. 4 December 2012.

4.        Citizens Demanding Justice. http://citizensdemandingjustice.blogspot.com/. 4 December 2012. 4 December 2012.

5.        Edds, Kimberly, Orange County Register Staff Writer. Orange County Register: Lying Social Worker Promoted. http://taxdollars.ocregister.com/2011/04/25/lying-social-worker-promoted-now-trains-others/81173/ . 25 April 2011. 4 December 2012.

6.        Armentano, Paul. Why Are We Testing Newborns for Pot.? AlterNet http://www.alternet.org/drugs/why-are-we-testing-newborns-pot. 23 November 2012. 4 December 2012.

7.        Davis, Walter and Lasher, Eileen. Progress in San Diego TV Show. Victories Against Family Court. http://youtu.be/bMB9gYhljfw. 28 May 2012. 4 December 2012.

8.        Rawles, Lee. Conspiracy of Silence Allowed Judges’ Kids for Cash Program Scandal to Occur. ABA Journal. http://www.abajournal.com/books/article/podcast_episode_015/?utm_source=maestro&utm_medium=email&utm_campaign=weekly_email . 12 November 2012. 4 December 2011.

9.        Davis, Walter. How Lynn Marie Li’s Children Were Taken and Sold. Citizens Demanding justice. http://citizensdemandingjustice.blogspot.com/2012/12/how-lynn-marie-les-kids-were-taken-and.html . 2 December 2012. 4 December 2012.

10.     Senate Bill No. 11. http://www.leginfo.ca.gov/pub/09-10/bill/sen/sb_0001-0050/sbx2_11_bill_20090220_chaptered.pdf  . 20 February 2009.  4 December 2012.

11.     Dutton, Leslie. Full Disclosure Network. http://blog.fulldisclosure.net/2009/09/deception-of-california-supreme-court.html 14 September 2009. 4 December 2012.

12.     Alliance of California Judges. http://allianceofcaliforniajudges.com/ . 4 December 2012. 4 December 2012.

13.     FOX Studio 11 Los Angeles. Lost in the System: Former Family Court Judge Speaks Out. http://www.myfoxla.com/video?autoStart=true&topVideoCatNo=default&clipId=7804013#.UG86rl0URBQ.blogger 4 December 2012. 4 December 2012.

14.     Windsor, William and Davis, Walter. Lawless America: Judge Bullock Complete Story. http://youtu.be/EjXdqi16Ixg. 4 October 2012. 4 December 2012.

15.     Vintage Judge Judith Sheindlin on 60 Minutes. http://youtu.be/FNQgcEstTbU 28 July 2012. 4 December 2012.

16.     Community Coalition Radio http://www.blogtalkradio.com/sdcommunitycoalition/2012/08/06/international-corruption-within-child-protective-services

17.     Windsor, William. Lawless America Dr. Richard Fine Promo Video. http://youtu.be/SgxyH1BZZsU. 1 October 2012. 4 December 2012.

18.     Coffman, David. Twenty Years of CAPTA. The Archaic CAPTA Legislation: Finscribes of Wisdom. 7 May 2012. 7 December 2012. http://finscribeofwisdom.blogspot.com/2012/05/archaic-capta-legislation.html?spref=bl

19.     Davis, Walter. Citizens Demanding Justice: How to Fight CPS – Pastor Wiley. 11 November 2012. 7 December 2012. http://citizensdemandingjustice.blogspot.com/2012/11/how-to-fight-cps-pastor-wiley.html

       20. Davis, Walter. Citizens Demanding Justice. Sharon Kramer: Wronged by the Courts- Jailed for Talking About It. 3 December 2012. 7 December 2012. http://citizensdemandingjustice.blogspot.com/2012/12/sharon-kramer-wronged-by-courts-jailed.html

Fwd: Recommend Infowars : New York Prostitution Ring Provided Minors For Wealthy Elitists

I recommend this page : New York Prostitution Ring Provided Minors For Wealthy Elitists. You can read it on : http://www.infowars.com/new-york-prostitution-ring-provided-minors-for-wealthy-elitists/

UNITED RUSSIA: PRESIDENT Vladimir Putin urges...

UNITED RUSSIA: PRESIDENT Vladimir Putin urges judges to stamp out CORRUPTION in COURT SYSTEM UNITED RUSSIA: PRESIDENT Vladimir Putin urges judges to stamp out CORRUPTION in COURT SYSTEM Moscow, Russia December 18, 2012 -Video from RIA Novosti (Видео ... View or comment on Walter Davis's post » Google+ makes sharing on the web more like sharing in real life. Learn more. Join Google+

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25 Facts The Mainstream Media Doesn’t Want To Talk About Right Now

25 Facts The Mainstream Media Doesn't Want To Talk About Right Now
Posted By:
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Sat Dec 29, 2012 7:54 pm |
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For decades, the mainstream media in the United States was accustomed to being
able to tell the American people what to think. Unfortunately for them, a whole
lot of Americans are starting to break free from that paradigm and think for
themselves. A Gallup survey from earlier this year found that 60 percent of all
Americans "have little or no trust" in the mainstream media. More people than
ever are realizing that the mainstream media is giving them a very distorted
version of "the truth" and they are increasingly seeking out alternative sources
of information.

In the United States today, just six giant media corporations control the
mainstream media. Those giant media corporations own television networks, cable
channels, movie studios, radio stations, newspapers, magazines, publishing
houses, music labels and even many prominent websites. But now thanks to the
Internet the mainstream media no longer has a complete monopoly on the news. In
recent years the "alternative media" has exploded in popularity. People want to
hear about the things that the corporate media doesn't really want to talk
about. They want to hear news that is not filtered by corporate bosses and
government censors. They want "the truth" and they know that they are not
getting it from the mainstream media.


We are watching a media revolution happen, and many in the mainstream media are
totally freaking out about it. In fact, some in the mainstream media have even
begun publishing articles that mock the American people for not trusting them.

For example, a recent CNN article entitled "Still `paranoid' after all these
years" portrayed Americans that don't trust the media as paranoid conspiracy
theorists that have left rationality behind…

Ever have the feeling you're being lied to by the news media, the authorities,
the corporate world? That somebody — or something — is out to get you? You're
not alone.
Welcome to 21st-century America.

Look around. Trust is hitting historic lows. Just a third of Americans have a
favorable view of the federal government, a decline of 31% since 2002, according
to the Pew Center for People and the Press. Gallup has Congress' approval rating
is in the low 20s, after nearing single digits last summer. And the news media
aren't much better off.

`Negative opinions about the performance of news organizations now equal or
surpass all-time highs on nine of 12 core measures the Pew Research Center has
been tracking since 1985,' a Pew report said.

The article goes on to make it sound like it is very irrational not to trust the
media, but in this day and age it is imperative that we all learn to think for
ourselves. Blindly trusting someone else to do your thinking for you is very
dangerous.

Anyone that does not acknowledge that the mainstream media has an agenda is not
being honest with themselves. The mainstream media presents a view of the world
that is very favorable to their big corporate owners and the big corporations
that spend billions of dollars to advertise on their networks. The mainstream
media is the mouthpiece of the establishment, and the worldview being pushed on
the big networks is going to be consistent with the economic, financial,
political and social goals of the establishment. The mainstream media loves to
talk about things that fit with that agenda, and they don't like to talk about
things that suggest that there is something wrong with that agenda.

The following are 25 facts that the mainstream media doesn't really want to talk
about right now…

#1 The mainstream media doesn't really want to talk about the fact that gun
sales are absolutely skyrocketing in the aftermath of the horrific tragedy at
Sandy Hook Elementary School.

#2 The mainstream media doesn't really want to talk about the fact that
disarming the population has resulted in some of the most horrific massacres in
human history. The following is from the Warrior Times…

1911 – Turkey disarmed its citizens, and between 1915 – 1917 they murdered 1.5
million Armenians.

1929 – Russia disarmed its citizens, and between 1929 – 1953 they murdered 20
million Russians.

1935 – China disarmed its citizens, and between 1948 – 1952 they murdered 20
million Chinese.

1938 – Germany disarmed its citizens, and between 1939 – 1945 they murdered 16
million Jews.

1956 – Cambodia disarmed its citizens, and between 1975 – 1977 they murdered 1
million Educated people.

1964 – Guatemala disarmed its citizens, and between 1964 – 1981 they murdered
100,000 Mayan Indians.

1970 – Uganda disarmed its citizens, and between 1971 – 1979 they murdered
300,000 Christians.

#3 The mainstream media doesn't really want to talk about the fact that a bill
allowing for the "indefinite military detention of US citizens on American soil"
was passed by the U.S. Senate on Friday.

#4 The mainstream media doesn't really want to talk about the fact that
volcanoes all along the Ring of Fire are roaring to life. It seems like a new
eruption is being reported every few days now. In fact, a red alert has just
been issued for a massive volcano that sits along the border between Chile and
Argentina.

#5 The mainstream media doesn't really want to talk about the fact that the use
of genetically engineered seeds has caused on explosion of new "super weeds"
that are incredibly difficult for farmers to kill.

#6 The mainstream media doesn't really want to talk about the fact that renowned
trends forecaster Gerald Celente is predicting a "financial disaster" in 2013.

#7 The mainstream media doesn't really want to talk about the fact that it is
easier to get into Harvard than it is to get a job as a flight attendant in
America today.

#8 The mainstream media doesn't really want to talk about the fact that nearly
400 TSA employees have been fired for stealing from travelers since 2003.

#9 The mainstream media doesn't really want to talk about the fact that giant
corporations such as Facebook are funneling gigantic amounts of money through
offshore banking havens such as the Cayman Islands in an effort to avoid taxes.

#10 The mainstream media doesn't really want to talk about the fact that the
U.S. dollar is in danger of losing its status as the primary reserve currency of
the world.

#11 The mainstream media doesn't really want to talk about the fact that Barack
Obama has gone off to vacation in Hawaii while the rest of the nation hopes for
a fiscal cliff deal to get done. Of course the mainstream media has to mention
that he is on vacation because they always keep track of what the president
does, but they are not making a big deal out of it because they love Obama. And
it sounds like Obama is having quite a good time on his little vacation…

The president is expected to indulge in some of his favorite pastimes on the
island where he was born and raised: golf, an expedition for the local treat
`shave ice,' and an evening out with family and friends. He hit the links at the
nearby Marine Corps base under sunny skies on Saturday afternoon.

#12 The mainstream media doesn't really want to talk about the fact that there
are government websites that give immigrants instructions about how to come over
to our country and apply for welfare.

#13 The mainstream media doesn't really want to talk about the fact that the
U.S. economy is losing millions of jobs to nations where it is legal to pay
workers slave labor wages. The mainstream media is totally married to the one
world economic agenda that their corporate owners make so much money from, and
so they say nothing as a steady stream of businesses and jobs continue to leave
the country.

#14 The mainstream media doesn't really want to talk about the fact that the
recent tax increase is causing large numbers of wealthy individuals to consider
moving out of the state of California.

#15 The mainstream media doesn't really want to talk about the fact that hunger
and poverty are absolutely exploding in the United States at the same time that
they are telling us that the economy is "recovering".

#16 The mainstream media doesn't really want to talk about the fact that North
Korea now has a three-stage rocket with enough range to potentially hit the
western United States.

#17 The mainstream media doesn't really want to talk about the fact that the
United States Postal Service is losing 25 million dollars a day and is on the
verge of financial collapse.

#18 The mainstream media doesn't really want to talk about the fact that our
biggest oil supplier in the Middle East, Saudi Arabia, still kills people for
changing religions.

#19 The mainstream media doesn't really want to talk about the fact that
political correctness is taking over America. The truth is that the media does
not see any problem with that at all.

#20 The mainstream media doesn't really want to talk about the fact that nearly
half a million employees of the federal government are making more than $100,000
a year.

#21 The mainstream media doesn't really want to talk about the fact that the
birth rate in the United States fallen to an all-time low. The elite are
actually absolutely thrilled that less babies are being born.

#22 The mainstream media doesn't really want to talk about the fact that violent
crime in the United States increased by 18 percent in 2011 and that many major
U.S. cities are seeing violent crime totally spiral out of control.

#23 The mainstream media doesn't really want to talk about the fact that Barack
Obama received more than 99 percent of the vote in more than 100 precincts in
Ohio on election day.

#24 The mainstream media doesn't really want to talk about the fact that during
the first four years of the Obama administration, the U.S. national debt grew by
about as much as it did from the time that George Washington took office to the
time that George W. Bush took office.

#25 The mainstream media doesn't really want to talk about the fact that the
Federal Reserve created the conditions for the last financial crisis and their
mismanagement of the economy has now brought us to the verge of another horrible
economic downturn. According to the mainstream media, the Federal Reserve is
"above politics" and should not be criticized.

Re: 25 Facts The Mainstream Media Doesn’t Want To Talk About Right Now

Dear DJ,


> Thank you for publishing these items.
>
> It would seem to justify that at least 25 good Americans, in each of the 3100 counties across America, who have had enough of this media abuse do two things....
>
> Join and support this organization:
>
> http://www.uscda.us/
>
>
> Then follow the instructions below:
>

CitySt.PaulMayorChrisColeman_Guilty HighCrimesMisdemeanorsMNConst3_SeparatePower

                               Wed.2Jan2013  HUMBLE PLEA TO ALL CITIZENS,TAXPAYERS

                                          http://www.blogger.com/home  Over 100 Blogs Forensic Files Extensive

                                                www.sharon4mnag.blogspot.com

       To the Above Named,Specifically Erin Murphy DFL64A, Sen.Dick Cohen 64 et al,

 Ramsey County Sheriff Matt Bostrom, son

                        of St.Paul City CouncilMan Dan Bostrom.* Police Chief Tom Smith, appointed by Coleman,Elected Ramsey Co. Attorney John Choi.

                " In 1881 the Minnesota legislature impeached Judge E. St. J. Cox for "frequenting bawdy houses and consorting with harlots."  Historical Pun Intended, na to Chris Coleman.

       AFFIDAVIT OF QUITAM RELATOR: VA Widow,CandidateAG

                        Sharon Anderson aka Peterson_Scarrella re: Penality Perjury.

                  On the Graves of Tenants in Common at 1058 Summit, Bill and Bernice A. Peterson, James R. Anderson, Sharons 2nd Disabled, SilverStar,Purple Heart Marine.      

         Has Standing to Criminally Charge the apparent Disbarred Lawyer current City St.Paul Mayor Chris Coleman former Clerk of Retired Judge Doris Huspeni (1988) former City Council Man with High Crimes,Misdemeanors since 1988 in his Personal and Official Capacity's. To 3Jan2013.

                              The charge of high crimes and misdemeanors covers allegations of misconduct peculiar to officials, such as perjury of oath, abuse of authority, bribery, intimidation, misuse of assets, failure to supervise, dereliction of duty, conduct unbecoming, and refusal to obey a lawful order. Offenses by officials also include ordinary crimes, but perhaps with different standards of proof and punishment than for nonofficials, on the grounds that more is expected of officials by their oaths of office.

                 

Click here: City of Saint Paul - Meeting of City Council on 1/4/2012 at 3:30 PM

http://stpaul.legistar.com/MeetingDetail.aspx?ID=181578&GUID=E42A6B36-0DEB-4D2C-90F2-1CAC8CB53815&Options=info|&Search=

                          Articles of Impeachment's RICO Patterned Enterprise

                             www.sharon4anderson.org  causing severe PSTD

It really bothers me that DFL St.Paul Mayor Chris Coleman in the Executive Branch uses his Appointment Power to use Elected Officials in the Legislative Branch, contrary to Separation of Powers Doctrine Chris Tolbert Lawyer in Hennepin Co. Attorneys Office,CityCouncilMan now League MN Cities www.lmc.org etc.

In Case you do not realize any/payout to the LandLords will come from the Citys Risk Managment," self insured" via www.lmc.org

http://www.commondreams.org/

* corruption: 1988 Heinous takings of our Home at 1058 Summit Ave.St.Paul,MN 55105 via Unpublished Opinion, apparantly written by Chris Coleman? up to the present City Council Agenda Jan3rd,2013

* betrayal of trust : Chris Coleman Executive BranchMayor, appointing Legislative City Council Elected Officials to various Boards,Commissions, Tax Supported contrary to MN Const.III.

* abuse of official power: Colemans Heinous Violations of OATH OF OFFICE, Conspiracy to cause Death,Disability,Disparagment of Titles, via DSI Employees, Stealing Cars,Trailers,Personal Propertys

* neglect of duty: Has Mayor Chris Coleman illegally used "Risk Managment" Funds derived from www.lmc.org for his lawyer buddy's

to manulipate and coverup the Major Serious Claims of "takings" without Just Compensation re: Metro Gang Strike Force 3 million insurance compensations denied to the LandLords and Alice Krengel,Sharon Anderson, Bill Dahn et al Judge Joanne Larsen Ericksen,

The IRS is responsible for enforcing the Internal Revenue Code (U.S.C.A. tit. 26), which codifies all U.S. tax laws. Basic IRS activities include serving and educating taxpayers; determining, assessing, and collecting taxes; investigating individuals and organizations that violate tax laws; determining Pension plan qualifications and exempt organization status; and issuing rulings and regulations to supplement the Internal Revenue Code.

* encroachment on Parliament's prerogatives: https://sharon4anderson.wordpress.com/2012/10/08/lawlessamerica_bill-windsor_sharonanderson_mnsenate64_judicial-holocaust/

* misapplication of funds>: www.taxthemax.blogspot.com

relative to USSC 10-1032 Magner v. Gallagher

https://sites.google.com/site/sharon4anderson/Home/aolfiles 

Sharons Propertys "taken" without Just Compensation even tho NO MORTGAGE AND TAXES WERE PAID.

1058 Summit,448 Desnoyer Duplex,2194 Marshall Duplex, 325 No.Wilder 6 unit,697 Surrey, in St. Paul,MN

.Courts & the 50 US State Supreme Courts and Weekly Practice Area Opinion Summaries Newsletters. Subscribe Now http://law.justia.com/constitution/us/article-3/18-standing.html

Standing to Challenge Lawfulness of Governmental Action

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Substantial Interest: Standing

Perhaps the most important element of the requirement of adverse parties may be found in the "complexities and vagaries" of the standing doctrine. "The fundamental aspect of standing is that it focuses on the party seeking to get his complaint before a federal court and not on the issues he wishes to have adjudicated."³³⁸ The "gist of the question of standing" is whether the party seeking relief has "alleged such a personal stake in the outcome of the controversy as to assure that concrete adverseness which sharpens the presentation of issues upon which the court so largely depends for illumination of difficult constitutional questions."³³⁹ This practical conception of standing has now given way to a primary emphasis upon separation of powers as the guide. "[T]he 'case or controversy' requirement defines with respect to the Judicial Branch the idea of separation of powers on which the Federal Government is founded. The several doctrines that have grown up to elaborate that requirement are 'founded in concern about the proper—and properly limited—role of the courts in a democratic society."'³⁴⁰

³³⁸ Flast v. Cohen, 392 U.S. 83, 99 (1968). That this characterization is not the view of the present Court, see Allen v. Wright, 468 U.S. 737, 750, 752, 755-56, 759-61 (1984). In taxpayer suits, it is appropriate to look to the substantive issues to determine whether there is a logical nexus between the status asserted and the claim sought to be adjudicated. Id. at 102; United States v. Richardson, 418 U.S. 166, 174-175 (1974); Duke Power Co. v. Carolina Envtl. Study Group, 438 U.S. 59, 78-79 (1978).
³³⁹ Baker v. Carr, 369 U.S. 186, 204 (1962). That persons or organizations have a personal, ideological interest sufficiently strong to create adverseness is not alone enough to confer standing; rather, the adverseness is the consequence of one being able to satisfy the Article III requisite of injury in fact. Valley Forge Christian College v. Americans United, 454 U.S. 464, 482-486 (1982); Schlesinger v. Reservists Comm. to Stop the War, 418 U.S. 208, 225-226 (1974). Nor is the fact that if plaintiffs have no standing to sue, no one would have standing, a sufficient basis for finding standing. Id. at 227.
³⁴⁰ Allen v. Wright, 468 U.S. 737, 750 (1984) (quoting Warth v. Seldin, 422 U.S. 490, 498 (1975)). All the standards relating to whether a plaintiff is entitled to adjudication of his claims must be evaluated "by reference to the Art. III notion that federal courts may exercise power only 'in the last resort, and as a necessity,' . . . and only when adjudication is 'consistent with a system of separated powers and [the dispute is one] traditionally thought to be capable of resolution through the judicial process."' Id. at 752 (quoting, respectively, Chicago & G.T. Ry. v. Wellman, 143 U.S. 339, 345 (1892), and Flast v. Cohen, 392 U.S. 83, 97 (1968)). For the strengthening of the separation-of-powers barrier to standing, see Lujan v. Defenders of Wildlife, 504 U.S. 555, 559-60, 571-78 (1992).

Standing as a doctrine is composed of both constitutional and prudential restraints on the power of the federal courts to render decisions,³⁴¹ and is almost exclusively concerned with such public law questions as determinations of constitutionality and review of administrative or other governmental action.³⁴² As such, it is often interpreted according to the prevailing philosophies of judicial activism and restraint and narrowly or broadly in terms of the viewed desirability of access to the courts by persons seeking to challenge legislation or other governmental action. The trend in the 1960s was to broaden access; in the 1970s, 1980s, and 1990s, it was to narrow access by stiffening the requirements of standing, although Court majorities were not entirely consistent. The major difficulty in setting forth the standards is that the Court's generalizations and the results it achieves are often at variance.³⁴³

³⁴¹ E.g., Valley Forge Christian College v. Americans United, 454 U.S. 464, 471-476 (1982); Allen v. Wright, 468 U.S. 737, 750-751 (1984).
³⁴² C. WRIGHT, HANDBOOK OF THE LAW OF FEDERAL COURTS 60 (4th ed. 1983).
³⁴³ "[T]he concept of 'Art. III standing' has not been defined with complete consistency in all of the various cases decided by this Court . . . [and] this very fact is probably proof that the concept cannot be reduced to a one-sentence or one-paragraph definition." Valley Forge Christian College v. Americans United, 454 U.S. 464, 475 (1982). "Generalizations about standing to sue are largely worthless as such." Association of Data Processing Service Orgs. v. Camp, 397 U.S. 150, 151 (1970). For extensive consideration of the doctrine, see Hart & Wechsler, supra at 107-196.

The standing rules apply to actions brought in federal courts, and they have no direct application to actions brought in state courts.³⁴⁴
Citizen Suits.—Persons do not have standing to sue to enforce a constitutional provision when all they can show or claim is that they have an interest or have suffered an injury that is shared by all members of the public. Thus, a group of persons suing as citizens to litigate a contention that membership of Members of Congress in the military reserves constituted a violation of Article I,� 6, cl. 2, was denied standing.³⁴⁵ "The only interest all citizens share in the claim advanced by respondents is one which presents injury in the abstract.... [The] claimed nonobservance [of the clause], standing alone, would adversely affect only the generalized interest of all citizens in constitutional governance."³⁴⁶
Taxpayer Suits.—Save for a narrow exception, standing is also lacking when a litigant attempts to sue to contest governmental action that he claims injures him as a taxpayer. In Frothingham v. Mellon,³⁴⁷ the Court denied standing to a taxpayer suing to restrain disbursements of federal money to those States that chose to participate in a program to reduce maternal and infant mortality; her claim was that Congress lacked power to appropriate funds for those purposes and that the appropriations would increase her taxes in future years in an unconstitutional manner. Noting that a federal taxpayer's "interest in the moneys of the Treasury . . . is comparatively minute and indeterminate" and that "the effect upon future taxation, of any payment out of the funds ... [is] remote, fluctuating and uncertain," the Court ruled that plaintiff had failed to allege the type of "direct injury" necessary to confer standing.³⁴⁸

³⁴⁴ Thus, state courts could adjudicate a case brought by a person without standing in the federal sense. If the plaintiff lost, he would have no recourse in the United States Supreme Court, inasmuch as he lacks standing, Tileston v. Ullman, 318 U.S. 44 (1943); Doremus v. Board of Education, 342 U.S. 429 (1952), but if plaintiff prevailed, the losing defendant may be able to appeal, because he might well be able to assert sufficient injury to his federal interests. ASARCO Inc. v. Kadish, 490 U.S. 605 (1989).
³⁴⁵ Schlesinger v. Reservists Comm. to Stop the War, 418 U.S. 208 (1974).
³⁴⁶ 418 U.S. at 217. See also United States v. Richardson, 418 U.S. 166, 176-177 (1974); Valley Forge Christian College v. Americans United, 454 U.S. 464, 483 (1982); Allen v. Wright, 468 U.S. 737, 754 (1984); Whitmore v. Arkansas, 495 U.S. 149 (1990); Lujan v. Defenders of Wildlife, 504 U.S. 555, 573-77 (1992). Cf. Ex parte Levitt, 302 U.S. 633 (1937); Laird v. Tatum, 408 U.S. 1 (1972).
³⁴⁷ Usually cited as Massachusetts v. Mellon, 262 U.S. 447 (1923), the two suits being consolidated.
³⁴⁸ 262 U.S. at 487, 488.

Taxpayers were found to have standing, however, in Flast v. Cohen,³⁴⁹ to contest the expenditure of federal moneys to assist religious-affiliated organizations. The Court asserted that the answer to the question whether taxpayers have standing depends on whether the circumstances of each case demonstrate that there is a logical nexus between the status asserted and the claim sought to be adjudicated. First, there must be a logical link between the status of taxpayer and the type of legislative enactment attacked; this means a taxpayer must allege the unconstitutionality only of exercises of congressional power under the taxing and spending clause of Article I, � 8, rather than also of incidental expenditure of funds in the administration of an essentially regulatory statute. Second, there must be a logical nexus between the status of taxpayer and the precise nature of the constitutional infringement alleged; this means the taxpayer must allege the challenged enactment exceeds specific constitutional limitations imposed upon the exercise of the taxing and spending power, rather than simply arguing that the enactment is generally beyond the powers delegated to Congress. Both Frothingham and Flast met the first test, because they attacked a spending program. Flast met the second test, because the Establishment Clause of the First Amendment operates as a specific limitation upon the exercise of the taxing and spending power, while Frothingham had alleged only that the Tenth Amendment had been exceeded. Reserved was the question whether other specific limitations constrained the taxing and spending clause in the same manner as the Establishment Clause.³⁵⁰
Since Flast, the Court has refused to expand taxpayer standing. Litigants seeking standing as taxpayers to challenge legislation permitting the CIA to withhold from the public detailed information about its expenditures as a violation of Article I, � 9, cl. 7, and to challenge certain Members of Congress from holding commissions in the reserves as a violation of Article I, � 6, cl. 2, were denied standing, in the former cases because their challenge was not to an exercise of the taxing and spending power and in the latter because their challenge was not to legislation enacted under Article I, � 8, but rather was to executive action in permitting Members to maintain their reserve status.³⁵¹ An organization promoting church-state separation was denied standing to challenge an executive decision to donate surplus federal property to a church-related college, both because the contest was to executive action under valid legislation and because the property transfer was not pursuant to a taxing and spending clause exercise but was taken under the property clause of Article IV, � 3, cl. 2.³⁵² It seems evident that for at least the foreseeable future taxpayer standing will be restricted to Establishment Clause limitations on spending programs.

³⁴⁹ 392 U.S. 83 (1968).
³⁵⁰ 392 U.S. at 105.
³⁵¹ United States v. Richardson, 418 U.S. 166 (1974); Schlesinger v. Reservists Comm. to Stop the War, 418 U.S. 208, 227-28 (1974). Richardson in its generalized grievance constriction does not apply when Congress confers standing on litigants. FEC v. Akins, 524 U.S. 11 (1998). When Congress confers standing on "any person aggrieved" by the denial of information required to be furnished them, it matters not that most people will be entitled and will thus suffer a "generalized grievance," the statutory entitlement is sufficient. Id. at 21-25.
³⁵² Valley Forge Christian College v. Americans United, 454 U.S. 464 (1982). The Court's present position on Flast is set out severely in Lewis v. Casey, 518 U.S. 343, 353 n.3 (1996), in which the Court largely plays down the "serious and adversarial treatment" prong of standing and strongly reasserts the separation-of-powers value of keeping courts within traditional bounds. The footnote is a response to Justice Souter's separate opinion utilizing Flast, id., 398-99, for a distinctive point.

Local taxpayers attacking local expenditures have generally been permitted more leeway than federal taxpayers insofar as standing is concerned. Thus, in Everson v. Board of Education,³⁵³ such a taxpayer was found to have standing to challenge the use of public funds for transportation of pupils to parochial schools.³⁵⁴ But in Doremus v. Board of Education,³⁵⁵ the Court refused an appeal from a state court for lack of standing of a taxpayer challenging Bible reading in the classroom. No measurable disbursement of public funds was involved in this type of activity, so that there was no direct injury to the taxpayer, a rationale similar to the spending program-regulatory program distinction of Flast.
Constitutional Standards: Injury in Fact, Causation, and Redressability.—While the Court has been inconsistent, it has now settled upon the rule that, "at an irreducible minimum," the constitutional requisites under Article III for the existence of standing are that the plaintiff must personally have suffered some actual or threatened injury that can fairly be traced to the challenged action of the defendant, and that the injury is likely to be redressed by a favorable decision.³⁵⁶

³⁵³ 330 U.S. 1 (1947).
³⁵⁴ See Bradfield v. Roberts, 175 U.S. 291, 295 (1899); Crampton v. Zabriskie, 101 U.S. 601 (1880); Heim v. McCall, 239 U.S. 175 (1915). See also Illinois ex rel. McCollom v. Board of Education, 333 U.S. 203 (1948); Zorach v. Clauson, 343 U.S. 306 (1952); Engel v. Vitale, 370 U.S. 421 (1962) (plaintiffs suing as parents and taxpayers).
³⁵⁵ 342 U.S. 429 (1952). Compare Alder v. Board of Education, 342 U.S. 485 (1952). See also Richardson v. Ramirez, 418 U.S. 24 (1974).
³⁵⁶ Valley Forge Christian College v. Americans United, 454 U.S. 464, 472 (1982); Allen v. Wright, 468 U.S. 737, 751 (1984); Lujan v. Defenders of Wildlife, 504 U.S. 555, 560-61 (1992). See, however, United States Parole Comm'n v. Geraghty, 445 U.S. 388 (1980), a class action case, in which the majority opinion appears to reduce the significance of the personal stake requirement. Id. at 404 n.11, reserving full consideration of the dissent's argument at 401 n.1, 420-21.

For some time, injury alone was not sufficient; rather, the injury had to be "a wrong which directly results in the violation of a legal right,"³⁵⁷ that is, "one of property, one arising out of contract, one protected against tortious invasion, or one founded in a statute which confers a privilege."³⁵⁸ The problem was that the "legal right" language was "demonstrably circular: if the plaintiff is given standing to assert his claims, his interest is legally protected; if he is denied standing, his interest is not legally protected."³⁵⁹ The observable tendency of the Court, however, was to find standing frequently in cases distinctly not grounded in property rights.³⁶⁰
In any event, the "legal rights" language has now been dispensed with. Rejection occurred in two administrative law cases in which the Court announced that parties had standing when they suffered "injury in fact" to some interest, "economic or otherwise," that is arguably within the zone of interest to be protected or regulated by the statute or constitutional provision in question.³⁶¹ Now political,³⁶² environmental, aesthetic, and social interests, when impaired, afford a basis for making constitutional attacks upon governmental action.³⁶³ The breadth of the injury in fact concept may be discerned in a series of cases involving the right of private parties to bring actions under the Fair Housing Act to challenge alleged discriminatory practices. The subjective and intangible interests of persons in enjoying the benefits of living in integrated communities were found sufficient to permit them to attack actions which threatened or harmed those interests even though the actions were not directed at them.³⁶⁴ In FEC v. Akins,³⁶⁵ the Court found "injury-in-fact" present when plaintiff voters alleged that the Federal Election Commission had denied them information, to which they alleged an entitlement, respecting an organization that might or might not be a political action committee. Congress had afforded persons access to the Commission and had authorized "any person aggrieved" by the actions of the FEC to sue to challenge the action. That the injury was widely shared did not make the claimed injury a "generalized grievance," the Court held, but rather in this case, as in others, it was a concrete harm to each member of the class. The case is a principal example of the ability of Congress to confer standing and to remove prudential constraints on judicial review. Similarly, the interests of individuals and associations of individuals in using the environment afforded them the standing to challenge actions which threatened those environmental conditions.³⁶⁶ Even citizens who bring qui tam actions under the False Claims Act, an action that entitles them to a percentage of any civil penalty assessed for violation, have been held to have standing, on the theory that the Government has assigned a portion of its damages claim to the plaintiff, and the asignee of a claim has standing to assert the injury in fact suffered by the assignor.³⁶⁷ Nonetheless, the Court has also in constitutional cases been wary of granting standing to persons who alleged threats or harm to interests which they shared with the larger community of people at large, a rule against airing "generalized grievances" through the courts,³⁶⁸ although it is unclear whether this rule (or subrule) has a constitutional or a prudential basis.³⁶⁹ And in a number of cases, the Court has refused standing apparently in the belief that the assertion of harm is too speculative or too remote to credit.³⁷⁰

³⁵⁷ Alabama Power Co. v. Ickes, 302 U.S. 464, 479 (1938). Cf. Joint Anti-Fascist Refugee Committee v. McGrath, 341 U.S. 123, 151-152 (1951) (Justice Frankfurter concurring). But see Frost v. Corporation Comm'n, 278 U.S. 515 (1929); City of Chicago v. Atchison, T. & S.F. Ry., 357 U.S. 77 (1958).
³⁵⁸ Tennessee Power Co. v. TVA, 306 U.S. 118, 137-138 (1939).
³⁵⁹ C. Wright, supra at 65-66.
³⁶⁰ E.g., Joint Anti-Fascist Refugee Committee v. McGrath, 341 U.S. 123 (1951) (indirect injury to organization and members by governmental maintenance of list of subversive organizations); NAACP v. Alabama ex rel. Patterson, 357 U.S. 449 (1958) (same); Abington School Dist. v. Schempp, 374 U.S. 203, 224 n. 9 (1963) (parents and school children challenging school prayers); McGowan v. Maryland, 366 U.S. 420, 430-431 (1961) (merchants challenging Sunday closing laws); Baker v. Carr, 369 U.S. 186, 204-208 (1962) (voting rights).
³⁶¹ Ass'n of Data Processing Service Org. v. Camp, 397 U.S. 150 (1970); Barlow v. Collins, 397 U.S. 159 (1970). The "zone of interest" test is a prudential rather than constitutional standard. The Court sometimes uses language characteristic of the language. Thus, in Lujan v. Defenders of Wildlife, 504 U.S. 555, 560 (1992), the Court refers to injury in fact as "an invasion of a legally-protected interest," but in context, here and in the cases cited, it is clear the reference is to any interest that the Court finds protectable under the Constitution, statutes, or regulations.
³⁶² Department of Commerce v. United States House of Representatives, 525 U.S. 316 (1999).
³⁶³ E.g., Lujan v. Defenders of Wildlife, 504 U.S. 555, 563 (1992); Lujan v. National Wildlife Federation, 497 U.S. 871, 885 (1991); Duke Power Co. v. Carolina Environmental Study Group, 438 U.S. 59, 72-74 (1978); Village of Arlington Heights v. Metropolitan Housing Dev. Corp., 429 U.S. 252, 261-263 (1977); Singleton v. Wulff, 428 U.S. 106, 112-113 (1976); Warth v. Seldin, 422 U.S. 490, 498-499 (1975); O'Shea v. Littleton, 414 U.S. 488, 493-494 (1974); Linda R.S. v. Richard D., 410 U.S. 614, 617-618 (1973).

³⁶⁴ Trafficante v. Metropolitan Life Ins. Co., 409 U.S. 205 (1972); Gladstone Realtors v. Village of Bellwood, 441 U.S. 91 (1979); Havens Realty Corp. v. Coleman, 455 U.S. 363 (1982). While Congress had provided for standing in the Act, thus removing prudential considerations affecting standing, it could not abrogate constitutional constraints. Gladstone Realtors, supra 100. Thus, the injury alleged satisfied Article III.
³⁶⁵ 524 U.S. 11 (1998).
³⁶⁶ Sierra Club v. Morton, 405 U.S. 727, 735 (1972); United States v. SCRAP, 412 U.S. 669, 687-88 (1973); Duke Power Co. v. Carolina Environmental Study Group, 438 U.S. 59, 72-74 (1978). But the Court has refused to credit general allegations of injury untied to specific governmental actions. E.g., Lujan v. Defenders of Wildlife, 504 U.S. 555 (1992); Lujan v. National Wildlife Federation, 497 U.S. 871 (1990). In particular, SCRAP, is disfavored as too broad. Lujan v. Defenders of Wild-life, 504 U.S. at 566. Moreover, unlike the situation in taxpayer suits, there is no requirement of a nexus between the injuries claimed and the constitutional rights asserted. In Duke Power, 438 U.S. at 78-81, claimed environmental and health injuries grew out of construction and operation of nuclear power plants but were not directly related to the governmental action challenged, the limitation of liability and indemnification in cases of nuclear accident. See also Metropolitan Washington Airports Auth. v. Citizens for the Abatement of Aircraft Noise, 501 U.S. 252, 264-65 (1991). Friends of the Earth v. Laidlaw Envtl. Servs., 528 U.S. 167 (2000).
³⁶⁷ Vermont Agency of Nat. Res. v. United States ex rel. Stevens, 529 U.S. 765 (2000). The Court confirmed its conclusion by reference to the long tradition of qui tam actions, since the Constitution's restriction of judicial power to "cases" and "controversies" has been interpreted to mean "cases and controversies of the sort traditionally amenable to, and resolved by, the judicial process." Id. at 1863.
³⁶⁸ See "Citizen Suits" supra.
³⁶⁹ Compare Warth v. Seldin, 422 U.S. 490, 499-500 (1975) (prudential), with Valley ForgeChristian College v. Americans United, 454 U.S. 464, 485, 490 (1982) (apparently constitutional). In Allen v. Wright, 468 U.S. 737, 751 (1984), it is again prudential.
³⁷⁰ E.g. Laird v. Tatum, 408 U.S. 1 (1972) ("allegations of a subjective 'chill'are not an adequate substitute for a claim of specific present objective harm or a threat of specific future harm."). See also O'Shea v. Littleton, 414 U.S. 488 (1974); California Bankers Ass'n v. Schultz, 416 U.S. 21 (1974); Rizzo v. Goode, 423 U.S. 262, 371-373 (1976). In City of Los Angeles v. Lyons, 461 U.S. 95 (1983), the Court held that victim of police chokehold seeking injunctive relief was unable to show sufficient likelihood of recurrence as to him.

Of increasing importance are the second and third elements of standing, causation and redressability, recently developed and held to be of constitutional requisite. There must be a causal connection between the injury and the conduct complained of; that is, the Court insists that the plaintiff show that "but for" the action, she would not have been injured. And the Court has insisted that there must be a "substantial likelihood" that the relief sought from the court if granted would remedy the harm.³⁷¹ Thus, poor people who had been denied service at certain hospitals were held to lack standing to challenge IRS policy of extending tax benefits to hospitals that did not serve indigents, since they could not show that alteration of the tax policy would cause the hospitals to alter their policies and treat them.³⁷² Low-income persons seeking the invalidation of a town's restrictive zoning ordinance were held to lack standing, because they had failed to allege with sufficient particularity that the complained-of injury, inability to obtain adequate housing within their means, was fairly attributable to the ordinance instead of to other factors, so that voiding of the ordinance might not have any effect upon their ability to find affordable housing.³⁷³ Similarly, the link between fully integrated public schools and allegedly lax administration of tax policy permitting benefits to discriminatory private schools was deemed too tenuous, the harm flowing from private actors not before the courts and the speculative possibility that directing denial of benefits would result in any minority child being admitted to a school.³⁷⁴ But the Court did permit plaintiffs to attack the constitutionality of a law limiting the liability of private utilities in the event of nuclear accidents and providing for indemnification, on a showing that "but for" the passage of the law there was a "substantial likelihood," based upon industry testimony and other material in the legislative history, that the nuclear power plants would not be constructed and that therefore the environmental and aesthetic harm alleged by plaintiffs would not occur; thus, a voiding of the law would likely relieve the plaintiffs of the complained of injuries.³⁷⁵ Operation of these requirements makes difficult but not impossible the establishment of standing by persons indirectly injured by governmental action, that is, action taken as to third parties that is alleged to have as a consequence injured the claimants.³⁷⁶

³⁷¹ Lujan v. Defenders of Wildlife, 504 U.S. 555, 595 (1992); Allen v. Wright, 468 U.S. 737, 751 (1984). See also ASARCO Inc. v. Kadish, 490 U.S. 605, 612-617 (1989) (plurality opinion). Although the two tests were initially articulated as two facets of a single requirement, the Court now insists they are separate inquiries. Id. at 753 n. 19. To the extent there is a difference, it is that the former examines a causal connection between the assertedly unlawful conduct and the alleged injury, whereas the latter examines the causal connection between the alleged injury and the judicial relief requested. Id. In Steel Co. v. Citizens for a Better Environment, 523 U.S. 83 (1998), the Court denied standing because of the absence of redressability. An environmental group sued the company for failing to file timely reports required by statute; by the time the complaint was filed, the company was in full compliance. Acknowledging that the entity had suffered injury in fact, the Court found that no judicial action would afford it a remedy.
³⁷² Simon v. Eastern Kentucky Welfare Rights Org., 426 U.S. 26 (1976). See also Linda R.S. v. Richard D., 410 U.S. 614 (1973) (mother of illegitimate child lacked standing to contest prosecutorial policy of utilizing child support laws to coerce support of legitimate children only, since it was "only speculative" that prosecution of father would result in support rather than jailing).
³⁷³ Warth v. Seldin, 422 U.S. 490 (1975). But in Village of Arlington Heights v. Metropolitan Housing Dev. Corp., 429 U.S. 252, 264 (1974), a person who alleged he was seeking housing in the community and that he would qualify if the organizational plaintiff were not inhibited by allegedly racially discriminatory zoning laws from constructing housing for low-income persons like himself was held to have shown a "substantial probability" that voiding of the ordinance would benefit him.
³⁷⁴ Allen v. Wright, 468 U.S. 737 (1984). But compare Heckler v. Mathews, 465 U.S. 728 (1984), where persons denied equal treatment in conferral of benefits were held to have standing to challenge the treatment, although a judicial order could only have terminated benefits to the favored class. In that event, members would have secured relief in the form of equal treatment, even if they did not receive benefits. And see Arkansas Writers' Project, Inc. v. Ragland, 481 U.S. 221 (1987); Orr v. Orr, 440 U.S. 268, 271-273 (1979).
³⁷⁵ Duke Power Co. v. Carolina Environmental Study Group, 438 U.S. 59, 72-78 1978). The likelihood of relief in some cases appears to be rather speculative at best. E.g., Bryant v. Yellen, 447 U.S. 352, 366-368 (1980); Watt v. Energy Action Educational Foundation, 454 U.S. 151, 160-162 (1981).
³⁷⁶ Warth v. Seldin, 422 U.S. 490, 505 (1975); Allen v. Wright, 468 U.S. 737, 756-761 (1984).

In a case permitting a plaintiff contractors' association to challenge an affirmative-action, set-aside program, the Court seemed to depart from several restrictive standing decisions in which it had held that the claims of attempted litigants were too "speculative" or too "contingent."³⁷⁷ The association had sued, alleging that many of its members "regularly bid on and perform construction work" for the city and that they would have bid on the set-aside contracts but for the restrictions. The Court found the association had standing, because certain prior cases under the equal protection clause established a relevant proposition. "When the government erects a barrier that makes it more difficult for members of one group to obtain a benefit than it is for members of another group, a member of the former group seeking to challenge the barrier need not allege that he would have obtained the benefit but for the barrier in order to establish standing. The 'injury in fact' in an equal protection case of this variety is the denial of equal treatment resulting from the imposition of the barrier, not the ultimate inability to obtain the benefit."³⁷⁸ The association, therefore, established standing by alleging that its members were able and ready to bid on contracts but that a discriminatory policy prevented them from doing so on an equal basis.³⁷⁹

³⁷⁷ Thus, it appears that had the Court applied its standard in the current case, the results would have been different in such cases as Linda R. S. v. Richard D., 410 U.S. 614 (1973); Warth v. Seldin, 422 U.S. 490 (1975); Simon v. Eastern Kentucky Welfare Rights Org., 426 U.S. 26 (1976); Allen v. Wright, 468 U.S. 737 (1984).
³⁷⁸ Northeastern Fla. Ch. of the Associated Gen. Contractors v. City of Jacksonville, 508 U.S. 656, 666 (1993). The Court derived the proposition from another set of cases. Turner v. Fouche, 396 U.S. 346 (1970); Clements v. Fashing, 457 U.S. 957 (1982); Regents of the Univ. of California v. Bakke, 438 U.S. 265, 281 n.14 (1978).
³⁷⁹ 508 U.S. at 666. But see, in the context of ripeness, Reno v. Catholic Social Services, Inc., 509 U.S. 43 (1993), in which the Court, over the dissent's reliance on Jacksonville, id. at 81-82, denied the relevance of its distinction between entitlement to a benefit and equal treatment. Id. at 58 n.19.

Redressability can be present in an environmental citizen suit even when the remedy is civil penalties payable to the government. The civil penalties, the Court explained, "carried with them a deterrent effect that made it likely, as opposed to merely speculative, that the penalties would redress [plaintiffs'] injuries by abating current violations and preventing future ones."³⁸⁰
Prudential Standing Rules.—Even when Article III constitutional standing rules have been satisfied, the Court has held that principles of prudence may counsel the judiciary to refuse to adjudicate some claims.³⁸¹ It is clear that the Court feels free to disregard any of these prudential rules in cases in which it thinks exceptionable circumstances exist,³⁸² and Congress is free to legislate away prudential restraints and confer standing to the extent permitted by Article III.³⁸³ The Court has identified three rules as prudential ones,³⁸⁴ only one of which has been a significant factor in the jurisprudence of standing. The first two rules are that the plaintiff's interest, to which she asserts an injury, must come within the "zone of interest" arguably protected by the constitutional provision or statute in question³⁸⁵ and that plaintiffs may not air "generalized grievances" shared by all or a large class of citizens.³⁸⁶ The important rule concerns the ability of a plaintiff to represent the constitutional rights of third parties not before the court.

³⁸⁰ Friends of the Earth v. Laidlaw Envtl. Servs., 528 U.S. 167, 187 (2000).
³⁸¹ Gladstone Realtors v. Village of Bellwood, 441 U.S. 91, 99-100 (1979) ("a plaintiff may still lack standing under the prudential principles by which the judiciary seeks to avoid deciding questions of broad social import where no individual rights would be vindicated and to limit access to the federal courts to those litigants best suited to assert a particular claim").
³⁸² Warth v. Seldin, 422 U.S. 490, 500-501 (1975); Craig v. Boren, 429 U.S. 190, 193-194 (1976).
³⁸³ "Congress may grant an express right of action to persons who otherwise would be barred by prudential standing rules. Of course, Art. III's requirement remains: the plaintiff still must allege a distinct and palpable injury to himself, even if it is an injury shared by a large class of other possible litigants." Warth v. Seldin, 422 U.S. 490, 501 (1975). That is, the actual or threatened injury required may exist solely by virtue of "statutes creating legal rights, the invasion of which creates standing, even though no injury would exist without the statute." Linda R.S. v. Richard D., 410 U.S. 614, 617 n. 3 (1973); O'Shea v. Littleton, 414 U.S. 488, 493 n. 2 (1974). Examples include United States v. SCRAP, 412 U.S. 669 (1973); Trafficante v. Metropolitan Life Ins. Co., 409 U.S. 205 (1972); Gladstone Realtors v. Village of Bellwood, 441 U.S. 91 (1979). See also Buckley v. Valeo, 424 U.S. 1, 8 n.4, 11-12 (1976). For a good example of the congressionally-created interest and the injury to it, see Havens Realty Corp. v. Coleman, 455 U.S. 363, 373-75 (1982) (Fair Housing Act created right to truthful information on availability of housing; black tester's right injured through false information, but white tester not injured because he received truthful information). It is clear, however, that the Court will impose separation-of-powers restraints on the power of Congress to create interests to which injury would give standing. Lujan v. Defenders of Wildlife, 504 U.S. 555, 571-78 (1992). Justice Scalia, who wrote the opinion in Lujan, reiterated the separation-of-powers objection to congressional conferral of standing in FEC v. Akins, 524 U.S. 11, 29, 36 (1998) (alleged infringement of President's ″take care″ obligation), but this time in dissent; the Court did not advert to this objection in finding that Congress had provided for standing based on denial of information to which the plaintiffs, as voters, were entitled.
³⁸⁴ Valley Forge Christian College v. Americans United, 454 U.S. 464, 474-75 (1982); Allen v. Wright, 468 U.S. 737, 751 (1984).
³⁸⁵ Ass'n of Data Processing Service Org. v. Camp, 397 U.S. 150, 153 (1970); Simon v. Eastern Kentucky Welfare Rights Org., 426 U.S. 26, 39 n. 19 (1976); Valley Forge Christian College v. Americans United, 454 U.S. 464, 475 (1982); Clarke v. Securities Industry Ass'n, 479 U.S. 388 (1987). See also Bennett v. Spear, 520 U.S. 154 (1997).
³⁸⁶ United States v. Richardson, 418 U.S. 166, 173, 174-176 (1974); Duke Power Co. v. Carolina Environmental Study Group, 438 U.S. 59, 80 (1978); Allen v. Wright, 468 U.S. 737, 751 (1984). In United States v. SCRAP, 412 U.S. 669, 687-688 (1973), a congressional conferral case, the Court agreed that the interest asserted was one shared by all, but the Court has disparaged SCRAP, asserting that it "surely went to the very outer limit of the law," Whitmore v. Arkansas, 495 U.S. 149, 159 (1990).

Standing to Assert the Constitutional Rights of Others.— Usually, one may assert only one's interest in the litigation and not challenge the constitutionality of a statute or a governmental action because it infringes the protectable rights of someone else.³⁸⁷ In Tileston v. Ullman,³⁸⁸ an early round in the attack on a state anticontraceptive law, a doctor sued, charging that he was prevented from giving his patients needed birth control advice. The Court held he had no standing; no right of his was infringed, and he could not represent

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