936-37 & n.6 (8th Cir. 2000); Taub v. Kentucky, 842 F.2d 912, 916 (6th Cir. 1988) ("Flast v. Cohen appears to create a fairly narrow exception to the [rule against taxpayer standing], and may apply only to Establishment Clause cases..."); see also Rocks v. City of Philadelphia, 868 F.2d 644,649 (3rd Cir. 1989). Indeed, since Flast, courts have expressly found that taxpayer standing is limited to Establishment Clause challenges. Colorado Taxpayers Union, Inc. v. Romer, 963 F.2d 1394,1399 (10th Cir. 1992) ("[T]he [Supreme] Court has indicated that Flast applies only to cases in which a federal taxpayer challenges a congressional appropriation made pursuant to Article 1, Section 8 that allegedly violates the Establishment Clause of the First Amendment.");
Pietsch v. Bush, 755 F. Supp. 62, 66 (E.D.N.Y.) ("The doctrine of 'taxpayer standing' is an extremely limited one; it can be invoked only 'to challenge Establishment Clause violations when the allegedly unconstitutional action was authorized by Congress under the taxing and spending clause of Art. I, § 8.'" (citing In re United States Catholic Conference, 885 F.2d 1020,1027 (2d Cir. 1989)), affd, 935 F.2d 1278 (2d Cir. 1991)(table). Thus, plaintiff's Article VI claims do not satisfy Flast's second prong, which limits taxpayer standing to Establishment Clause challenges.10 In sum, plaintiff cannot establish taxpayer standing to raise any Article VI claim.
2.     Plaintiff's Allegations of Personal Reproach Fail to Meet the Prerequisites for Article III Standing.
In addition to his alleged injury as a taxpayer, plaintiff alleges that he suffered a "personal reproach" from a prayer offered by the Senate Chaplain to open the Senate's daily session on June
10 The insufficiency of plaintiff's alleged taxpayer injury to create standing to raise his Article VI claims is demonstrated by the fact that the redress sought for his taxpayer injuries -enjoining the spending of the challenged funds - would not redress the alleged Article VI constitutional violations. Even if the Court enjoined the payment of salary to the House and Senate Chaplains, it would not redress plaintiffs claim that the chaplaincies themselves are subject to an unconstitutional religious test or that the Chaplain's prayers have violated the Supremacy Clause and his oath of office.
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