Frothingham v. Mellon and Massachusetts v. Mellon, considered together by the U.S. Supreme Court, challenged the Sheppard-Towner Act of 1921, otherwise known as the Sheppard-Towner Maternity And Infancy Protection Act or informally as the Maternity Act.
What the Plaintiffs Wanted
In these cases, the state of Massachusetts and a private citizen asked that the court stop the expenditure of federal funds under that act, which provided federal matching grants to states for various programs "to reduce maternal and infant mortality" under supervision of the U.S. Children's Bureau.
The challenge alleged that the federal expenditures violated the tenth amendment and was a deprivation of property without due process.
Supreme Court Decision and Reasoning
The Supreme Court of the United States, in an opinion written by Justice George Sutherland, unanimously dismissed the case. The suit of Massachusetts, which refused funding, was dismissed because the state could refuse the funding and because no actual rights of property or "quasi-sovereign" rights were involved. The suit by Frothingham, a due process claim, was dismissed because Frothingham could show no direct injury, because any tax effects would be "comparatively minute and indeterminable."
The Supreme Court refused to consider the merits of the cases, instead finding no justiciable controversy and no standing to sue.
Significance
The Supreme Court's action in Frothingham v. Mellon and Massachusetts v. Mellon is significant because, as these were challenges to the first federal funding of a social welfare program -- one denounced as "socialistic" by such organizations as the American Medical Association -- the Court did not declare such federal funding to be unconstitutional. The Court would not find on the constitutionality of such funding for several more years.
