In the case of Simon, Secretary of the Treasury, et al. v. Eastern Kentucky Welfare Rights Organization et al., 1975, the U.S Supreme Court ruled that a group representing low-income individuals did not have standing to challenge an Internal Revenue Service (IRS) ruling which allowed hospitals to qualify for tax-exempt status even if they only provided limited services to those unable to pay. The court held that there was no direct link between IRS's actions and any harm suffered by these individuals as it could not be proven conclusively that revoking a hospital’s tax-exempt status would lead them to offer more services for indigent patients. Therefore, their complaint did not meet the "case or controversy" requirement necessary under Article III of Constitution and thus lacked legal standing in federal courts.

In the dissenting opinion for Simon v. Eastern Kentucky Welfare Rights Organization, Justice Thurgood Marshall argued that the majority had set an overly restrictive standard for determining standing to sue in federal court. He believed that the plaintiffs, low-income individuals who were denied access to hospital services due to a change in IRS policy favoring non-profit hospitals providing less uncompensated care, should have been able to challenge this policy in court. According to Justice Marshall, these individuals suffered direct harm from this policy and thus met all traditional criteria for standing: injury-in-fact, causation and redressability. By denying them their day in court based on speculative arguments about whether striking down the IRS rule would lead hospitals to provide more charity care or not was unjustified according his view.