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===Taxpayer standing=== The initial case that established the doctrine of standing, ''[[Frothingham v. Mellon]]'', was a taxpayer standing case.<ref name=Frothingham/> Taxpayer standing is the concept that any person who pays taxes should have standing to file a [[lawsuit]] against the taxing body if that body allocates funds in a way that the [[taxpayer]] feels is improper. The [[United States Supreme Court]] has held that taxpayer standing is not by itself a sufficient basis for standing against the [[United States government]].<ref>{{ussc|name=Flast v. Cohen|volume=392|page=83|pin=|year=1968}}.</ref> The Court has consistently found that the conduct of the federal government is too far removed from individual taxpayer returns for any injury to the taxpayer to be traced to the use of tax revenues, e.g., ''[[United States v. Richardson]].'' In ''[[DaimlerChrysler Corp. v. Cuno]]'',<ref>{{ussc|name=DaimlerChrysler Corp. v. Cuno|volume=547|page=332|pin=|year=2006}}.</ref> the Court extended this analysis to state governments as well. However, the Supreme Court has also held that taxpayer standing is constitutionally sufficient to sue a [[municipal government]] in a [[United States federal court|federal court]].<ref>{{Cite web|url=https://www.law.cornell.edu/constitution-conan/article-3/section-2/clause-1/substantial-interest-standing|title=Substantial Interest: Standing|website=LII / Legal Information Institute}}</ref> States are also protected against lawsuits by their [[sovereign immunity]]. Even where states waive their sovereign immunity, they may nonetheless have their own rules limiting standing against simple taxpayer standing against the state. Furthermore, states have the power to determine what will constitute standing for a litigant to be heard in a state court, and may deny access to the courts premised on taxpayer standing alone. In [[California]], taxpayers have standing to sue for any 'illegal expenditure of, waste of, or injury to the estate, funds, or other property of a local agency'.<ref>{{calccp|526a|}}</ref> In [[Florida]], a taxpayer has standing to sue if the state government is acting unconstitutionally with respect to public funds, or if government action is causing some special injury to the taxpayer that is not shared by taxpayers in general. In [[Virginia]], the [[Supreme Court of Virginia]] has more or less adopted a similar rule. An individual taxpayer generally has standing to challenge an act of a city or county where they live, but does not have general standing to challenge state expenditures.
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