# Laird v. Tatum **Status: stub — expand.** **408 U.S. 1 (1972). Decided June 26, 1972. Burger, C.J., 5–4.** Plaintiffs challenged U.S. Army surveillance of lawful civilian political activity conducted after the 1967–68 civil disturbances. The Court held they lacked Article III standing: a subjective "chilling effect" arising from the mere existence of a government data-gathering program is not an injury in fact. Its relevance to domestic deployment is procedural rather than substantive. *Laird* is a large part of why the 2025–26 federalization suits were brought by **states and cities asserting sovereign and proprietary injury** rather than by the protesters the troops were sent to face. It decides nothing about 10 U.S.C. § 12406 or the [[Insurrection Act]]. ## See also - [[National Guard Federalization Flow]] · [[National Guard]] · [[Posse Comitatus Act]] · [[Insurrection Act]]