representation doctrine). We decline to adopt this doctrine. The doctrine of virtual representation apparently originated in the eighteenth century as a means by which courts of equity could “bind persons holding remainder and reversionary interests in real property to a decree adjudicating property rights as long as the owner of the first vested estate of inheritance . . . was made a party to the suit.” Bone, 67 N.Y.U. L. Rev. at 206. The nineteenth century saw an expansion of the doctrine beyond its real property origins. Id. at 209-11. Taxpayers, for example, were held to be bound by prior judgments entered in “public rights suits” challenging the legitimacy of government action. Id. at 210 (citing Harmon v. Auditor of Public Accounts, 123 Ill. 122, 132, 13 N.E. 161, 163-64 (1887) (<HOLDING>)). The doctrine of virtual representation fell
holding the rule against taxpayer standing applies both to federal taxpayers and state taxpayers challenging state tax or spending decisions simply by virtue of their status as state taxpayers holding that the nature of the taxpayers legal interest in the subject property is determined by reference to state law holding that a challenge by taxpayers and property owners to the issuance of municipal bonds was barred by a judgment entered in a prior action recognizing that taxpayers are not entitled to interest on cash bonds holding that challenge to state proceeding was barred by younger even if it was not barred by rookerfeldman