Watson v. Fox
Annotate this CasePlaintiff Robert Watson, together with nine Republican colleagues from the Rhode Island House of Representatives, sought a declaration that the process the General Assembly used to allocate $2.3 million in state money for legislative grants to local and private organizations in the 2008 fiscal year violated the Rhode Island Constitution. Plaintiffs brought the action in their individual capacities as taxpayers, and not in their capacities as elected officials. The superior court dismissed the action for failure to state a claim upon which relief could be granted, finding that Plaintiffs lacked standing to bring their claim because Rhode Island does not recognize so-called "taxpayer standing," and because Plaintiffs were unable to articulate a particularized injury that was distinct from any suffered by the general public. Watson appealed. The Supreme Court affirmed, holding (1) Plaintiff did not have standing under the Court's precedent; and (2) the substantial public interest exception did not apply in this case.
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