905 F.3d 432
6th Cir.2018Background
- Jeremy Durham, a Tennessee state representative, was expelled by the Tennessee House during a 2016 special session.
- Had he retired, Durham may have qualified for lifetime health insurance and certain pension benefits; after expulsion administrators informed him his coverage would end and benefits would be denied.
- Durham sued state administrators under 42 U.S.C. § 1983, alleging the House’s expulsion violated his Fourteenth Amendment procedural due process rights and that administrators enforced denial of benefits based on that expulsion.
- Defendants moved to dismiss for lack of Article III standing (Rule 12(b)(1)) and for failure to state a claim (Rule 12(b)(6)); the district court dismissed for lack of standing without reaching the merits.
- The Sixth Circuit reviewed only the standing question: whether Durham’s alleged injury (denial of benefits) is fairly traceable to the administrators’ conduct and redressable by ordering them to pay.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Article III causation for standing: Is the injury fairly traceable to the named defendants? | Durham: The harm is denial of benefits by administrators, so injury is traceable to them and redressable by court order to pay. | Administrators: The expulsion by the legislature was the cause; administrators merely implemented it, so Durham lacks causation and standing. | Court: Durham has standing—injury (denied benefits) is fairly traceable to administrators who denied/pay benefits and is redressable by ordering payment. |
Key Cases Cited
- Steel Co. v. Citizens for a Better Env’t, 523 U.S. 83 (standing requires injury, causation, redressability)
- Lujan v. Defs. of Wildlife, 504 U.S. 555 (causation requires injury be fairly traceable to defendant, not result of independent third-party action)
- Kitchen v. Herbert, 755 F.3d 1193 (10th Cir.) (officials who implement policy can be sued when they have authority to enforce complained-of provision)
- Duke Power Co. v. Environmental Study Group, 438 U.S. 59 (standing met despite defendants’ lawful actions because injuries were fairly traceable)
- Strickland v. Alexander, 772 F.3d 876 (11th Cir.) (ministerial or lawful implementation by an official does not defeat causation for standing)
- Pennhurst State School & Hospital v. Halderman, 465 U.S. 89 (limits on relief and Eleventh Amendment considerations but does not negate standing)