Cases construing the prudential component of the standing doctrine have relied on the avoidance doctrine. Prudence gives rise to, among other doctrines, the prohibition against third-party standing.Singleton v. Wulff, 428 U.S. 106, 124 (Powell, J., concurring in part and dissenting in part) (citing Brandeis' discussion of the avoidance doctrine in Ashwander). As a general rule, a litigant can raise only her own claims, not those of another. Third party standing also implicates the basic concept of a right, which includes the power of the rightholder to choose whether to exercise that right. One policy underlying the prohibition is the desire to avoid unnecessary constitutional adjudication.Singleton, 428 U.S. at 124 n.3 (Powell, J., concurring in part and dissenting in part). A second justification for the prohibition against third-party standing is the court's need for effective advocacy through a traditional controversy. Id. The court, in explicating the bar against third-party standing, has described Brandeis' Ashwander rules as "offering the standing requirement as one means by which courts avoid unnecessary constitutional adjudications."Singleton, 428 U.S. at 114. A second prudential restriction is the bar against finding standing for a generalized grievance — a harm shared in substantially equal measure by all or a large group of citizens.See, e.g., City of Los Angeles v. Lyons, 461 U.S. 95, 111 (1983) (person injured by police "chokehold" could seek damages but had no standing to seek injunctive relief against future use of "chokehold" because he could not show sufficient likelihood of imminent personal harm and irreparable injury); Warth v. Seldin, 422 U.S. 490, 499 (1975); Schlesinger v. Reservists Comm. to Stop the War, 418 U.S. 208, 221-27 (1974). The court has also linked this standing bar to the avoidance doctrine: the requirement of an individualized injury serves to ensure that "there is a real need to exercise the power of judicial review in order to protect the interests of the complaining party."Schlesinger, 418 U.S. at 221 (emphasis added) (challenging holding of Armed Forces Reserve commissions by members of Congress under Incompatibility Clause of Article I, § 6). The court also found the avoidance doctrine "particularly applicable" in Schlesinger because the litigants sought an interpretation of a constitutional provision which had not been construed by the federal courts. Indeed, the avoidance doctrine may be an early formulation of the justiciability doctrines.
