Representative Bob Schaffer and three others challenge the cost-of-living increases in the Ethics Reform Act of 1989, arguing that such automatic increases grant legislators raises before a new Congressional session begins. In Schaffer v. Clinton, the district court dismisses three of the plaintiffs (a state legislator, a taxpayer, and a voter), on the ground that they have no standing to bring the case. The court dismisses case finding that the cost-of-living raises accomplish the goal of the Twenty-seventh Amendment because they “eliminate the possibility that Congress will grant itself a new pay raise during its current session.” The court of appeals dismisses the appeal because Schaffer, by receiving the pay increase, has not suffered any real injury.