Roe v. Town of New Fairfield
To possess standing, a citizen "must prove the [government's action] has directly or indirectly increased [his] taxes [or otherwise] caused [the citizen] irreparable injury in [his] capacity as a taxpayer," pursuant to Seymour v. Region One Board of Education, a Connecticut Supreme Court decision. The plaintiff, who resides in the Town of New Fairfield, alleged that the first selectman reached agreement to purchase real property on behalf of the municipality without prior approval at a town meeting or from the board of selectmen. The plaintiff requested a declaratory judgment that the defendant first selectman exceeded his powers. The defendant moved to dismiss and argued that the plaintiff lacked standing. The plaintiff objected that he possesses standing as a taxpayer and a voter. A plaintiff who is a taxpayer does not automatically possess standing to protest government action. The plaintiff must establish that the plaintiff is directly affected in a pecuniary way or that the plaintiff has suffered a tangible injury. The plaintiff's complaint did not allege that his taxes will increase, because of the municipality's purchase. The plaintiff's complaint failed to allege any specific or tangible injury, as a result of the municipality's purchase of the property. The plaintiff's complaint also did not request that the court order that the board of selectmen call a town meeting. The plaintiff failed to raise his right to vote at a town meeting, and the court found that the plaintiff did not possess standing as a voter. The court granted the defendant's motion to dismiss.