In the case of Common Cause et al. v. Schmitt et al., 1981, a non-profit advocacy organization and several individual taxpayers sued to prevent Congress from receiving an automatic pay increase that they argued was unconstitutional under Article I, Section 6 of the U.S Constitution which requires that "No law varying the compensation for services of Senators and Representatives shall take effect until an election of representatives has intervened." The plaintiffs sought injunctive relief to stop payment increases scheduled for October 1st without a recorded vote by Congress. However, both district court and Supreme Court dismissed their claims on grounds that neither party had standing to sue as they failed to show any personal injury resulting from this action. The Supreme Court held that taxpayer status alone is insufficient basis for challenging legality or constitutionality of federal spending programs; it also ruled out organizational standing since no direct injuries were demonstrated.

In the dissenting opinion for COMMON CAUSE et al. v. SCHMITT et al., 1981, it was argued that the majority's decision to dismiss the case due to lack of jurisdiction was incorrect and premature. The dissenters believed that there were significant constitutional questions at stake regarding campaign finance laws which required immediate attention from the Supreme Court. They contended that by dismissing this case on procedural grounds, rather than addressing these substantive issues head-on, the court failed in its duty to provide a definitive interpretation of federal law and constitutionality related to political contributions and expenditures limits set by Federal Election Campaign Act (FECA). Furthermore, they expressed concern about potential implications for future cases involving similar issues if left unaddressed or unresolved.