AI-generated
Updated 31st March 2025
Tileston vs. Ullman
The Supreme Court dismissed an appeal by a physician challenging the constitutionality of a Connecticut law prohibiting the use of contraceptives, holding that the physician lacked standing to assert the constitutional rights of his patients.

Primary Holding

A physician lacks standing to challenge a state statute prohibiting contraception on the grounds that it deprives the physician's patients of life without due process, as the right to life is personal and must be asserted by the patients themselves.

Background

A physician brought a suit seeking a declaratory judgment that a Connecticut law banning contraception was unconstitutional. The physician argued that the law prevented him from providing necessary medical advice to patients whose lives would be endangered by pregnancy.

History

  • The case began in Connecticut state court.

  • The Superior Court of Connecticut reserved questions of law for the Supreme Court of Errors of Connecticut.

  • The Supreme Court of Errors of Connecticut held that the statutes applied to the appellant and were constitutional.

  • The case was then appealed to the U.S. Supreme Court.

  • The U.S. Supreme Court dismissed the appeal.

Facts

  • 1. A registered physician, Tileston, alleged that Connecticut statutes prevented him from advising three patients about using contraceptives.
  • 2. These patients had medical conditions such that pregnancy would endanger their lives.
  • 3. State law enforcement officers intended to prosecute any violations of the statute.
  • 4. Tileston sought a declaratory judgment on the statute's applicability and constitutionality under the Fourteenth Amendment.

Arguments of the Petitioners

  • 1. The physician argued that the Connecticut statute, if applied to him, would deprive his patients of their right to life without due process of law, violating the Fourteenth Amendment.

Arguments of the Respondents

  • 1. The State of Connecticut argued that the statutes were constitutional and applicable to the physician, representing a valid exercise of state power.

Issues

  • 1. Does a physician have standing to assert the constitutional rights of their patients in challenging a state law prohibiting contraception?

Ruling

  • 1. The Supreme Court held that the physician lacked standing to assert his patients' rights. The Court reasoned that the constitutional right to life allegedly violated belonged to the patients, not the physician. Since the patients were not parties to the suit and had not asserted their rights, the physician could not do so on their behalf.

Doctrines

  • 1. Standing: This doctrine requires a party to have a sufficient connection to and harm from the law or action challenged to support that party's participation in the case. In this case, the physician lacked standing because the alleged harm was to his patients, not himself.
  • 2. Fourteenth Amendment (Due Process Clause): While the petitioner invoked this, the court did not rule on the merits of the Due Process claim.

Precedents Cited

  • 1. Cronin v. Adams, 192 U. S. 108, 114: Cited to support the principle that one cannot litigate the constitutional rights of another.
  • 2. Standard Stock Food Co. v. Wright, 225 U. S. 540, 550: Cited for the same principle as above.
  • 3. Bosley v. McLaughlin, 236 U. S. 385, 395: Cited for the same principle as above.
  • 4. Blair v. United States, 250 U. S. 273: Cited for the same principle as above.
  • 5. The Winnebago, 205 U.S. 354, 360: Cited for the same principle as above.
  • 6. Davis & Farnum Mfg. Co. v. Los Angeles, 189 U. S. 207, 220: Cited for the same principle as above.
  • 7. Nashville, C. & St. L. Ry. Co. v. Wallace, 288 U. S. 249, 259: Cited regarding the existence of a genuine case or controversy essential to the Court's jurisdiction (though the Court did not rule on this).

Statutory and Constitutional Provisions

  • 1. U.S. Constitution, Amendment XIV: Cited as the basis for the constitutional challenge, alleging deprivation of life without due process.
  • 2. Connecticut General Statutes §§ 6246 and 6562 (1930): These statutes prohibited the use of drugs or instruments to prevent conception and the giving of assistance or counsel in their use.