Justice Harlan argues that the majority’s test is flawed because it does not actually measure a taxpayer’s “personal stake,” which is supposed to be the constitutional requirement for standing. Instead, he sees the test as arbitrary line‑drawing that does not reflect real differences in injury or interest. His dissent warns that the Court’s new doctrine risks opening the door to broad public‑action lawsuits that could distort the judiciary’s role and upset separation‑of‑powers principles.

The Court invokes Madison’s Memorial and Remonstrance to show that the Framers specifically feared the use of tax dollars to support religion. This historical argument strengthens the Court’s claim that the Establishment Clause is a specific limitation on the taxing and spending power.

The Court is carving out a narrow exception to the general rule that taxpayers lack standing. The two‑part nexus requirement is designed to prevent courts from becoming forums for generalized political grievances. The first nexus ensures the challenge is tied to Congress’s taxing and spending power; the second ensures the claim is based on a specific constitutional limitation, not a broad structural objection. This becomes the doctrinal foundation for taxpayer standing in Establishment Clause cases.