, of any payment out of the funds, so remote, fluctuating
and uncertain, that no basis is afforded for an appeal to the preventive
powers of a court of equity."[164] Likewise, the Court has held that the
general interest of a citizen in having the government administered by
law does not give him a standing to contest the validity of governmental
action.[165] Nor can a member of the bar of the Supreme Court challenge
the validity of an appointment to the Court since his "is merely a
general interest common to all members of the public."[166] Similarly an
electric power company has been held not to have a sufficient interest
to maintain an injunction suit to restrain the making of federal loans
and grants to municipalities for the construction or purchase of
electric power distribution plants on the ground that the "lender owes
the sufferer no enforcible duty to refrain from making the unauthorized
loan; and the borrower owes him no obligation to refrain from using the
proceeds in any lawful way the borrower may choose."[167] Recent cases,
involving the issue of religion in the schools, reach somewhat divergent
results. In Illinois ex rel. McCollum _v._ Board of Education,[168] the
Court held that a litigant had the requisite standing to bring a
mandamus suit challenging, on the basis of her interests as a resident
and taxpayer of the school district and the parent of a child required
by law to attend the school or one meeting the State's educational
requirements, the validity of a religious education program involving
the use of public school rooms one half hour each week. But in Doremus
_v._ Board of Education,[169] decided early in 1952, the Court declined
jurisdiction in a case challenging the validity of a New Jersey statute
which requires the reading at the opening of each public school day of
five verses of the Old Testament. Appellants' interest as taxpayers was
found to be insufficient to sustain the proceeding.

Substantial Interest in Suits by States

These principles have been applied in a number of cases to which a State
was one of the parties and in suits between States. One of the most
important of these is State of Georgia _v._ Stanton,[170] which was an
original suit in equity brought by the State of Georgia against the
Secretary of War and others to enjoin the enforcement of the
Reconstruction Acts. The State's counsel contended that enforcement of
the acts brought about "an immediate paralysis of all