Los Angeles v. Lyons, 461 U.S. 95 (1983)

Article III of the Constitution empowers federal courts to only hear ‘‘cases and controversies.’’ When determining whether there is a case or controversy, federal courts will determine whether the plaintiff has standing, which requires, inter alia, that a government practice caused or will cause an actual or imminent injury. In City of Los Angels v. Lyons, the Supreme Court extended this doctrine to hold that the plaintiff must have standing not only to file suit, but also to seek injunctive relief.

Adolph Lyons, an African-American man, was stopped after committing a minor traffic offense. The Los Angeles Police Department had a practice of placing nonviolent offenders in choke holds, even though the practice killed sixteen people—twelve of whom were African-American men. Thus, although Lyons did resist arrest, they placed him in a choke hold. Lyons lost consciousness.

Lyons then filed a federal Civil Rights Lawsuit. He sought compensatory and injunctive relief, that is, he asked the federal court to force the LAPD to stop choking nondangerous offenders. Although the Supreme Court recognized that Lyons had standing to seek money damages, a five-to-four Court held that he lacked standing to seek an injunction. Justice White wrote for the Court that it was ‘‘no more than speculation to assert either that Lyons himself will again be involved in one of those unfortunate instances [].’’ Consequently, Lyons did not face an imminent injury and therefore lacked standing to seek an injunction. Under Lyons’ standing requirement, plaintiffs seeking to wholesale stop a dangerous practice face an almost insurmountable hurdle.

MICHAEL C. CERNOVICH

References and Further Reading

• Fan, Mary D., Risk Magnified: Standing Under the Statist Lens, Yale Law Journal 112 (2003).
• Tribe, Lawrence H. American Constitutional Law. 3rd Ed. 1999, pp. 411.

Cases and Statutes Cited

• City of Los Angeles v. Lyons, 461 U.S. 95 (1983)

See also Jurisdiction of the Federal Courts; Race and Criminal Justice