City of Los Angeles v. Lyons
Encyclopedia
City of Los Angeles v. Lyons, 461 U.S. 95 (1983) was a United States Supreme Court decision holding that the plaintiff, Adolph Lyons, lacked standing
to challenge the city police department's alleged chokehold policy. Lyons, an African American, had been subjected to a chokehold after being stopped for a traffic violation. He sought both compensatory damages for the chokehold, and declaratory and injunctive relief against the department's chokehold policy (he introduced evidence that from 1975 to 1983, sixteen people, including twelve African Americans, had been killed by police chokeholds). In an opinion authored by Justice White
, the Court held, 5-4, that Lyons had failed to allege a sufficiently plausible threat of future injury to have standing for an injunction
; Lyons did, however, have standing for his damages action, since this was retrospective and the injury--being subjected to the chokehold--was concrete and particular. The decision helps establish the principle that a plaintiff must meet a standing requirement for each form of relief sought. Justice Marshall
's dissent argued that the majority's test would immunize from review any widespread policy that deprives constitutional rights when individuals cannot show with certainty that they would be subject to a repeat violation. He also argued that the Court's traditional rule did not distinguish different forms of relief for standing purposes.
Standing (law)
In law, standing or locus standi is the term for the ability of a party to demonstrate to the court sufficient connection to and harm from the law or action challenged to support that party's participation in the case...
to challenge the city police department's alleged chokehold policy. Lyons, an African American, had been subjected to a chokehold after being stopped for a traffic violation. He sought both compensatory damages for the chokehold, and declaratory and injunctive relief against the department's chokehold policy (he introduced evidence that from 1975 to 1983, sixteen people, including twelve African Americans, had been killed by police chokeholds). In an opinion authored by Justice White
Byron White
Byron Raymond "Whizzer" White won fame both as a football halfback and as an associate justice of the Supreme Court of the United States. Appointed to the court by President John F. Kennedy in 1962, he served until his retirement in 1993...
, the Court held, 5-4, that Lyons had failed to allege a sufficiently plausible threat of future injury to have standing for an injunction
Injunction
An injunction is an equitable remedy in the form of a court order that requires a party to do or refrain from doing certain acts. A party that fails to comply with an injunction faces criminal or civil penalties and may have to pay damages or accept sanctions...
; Lyons did, however, have standing for his damages action, since this was retrospective and the injury--being subjected to the chokehold--was concrete and particular. The decision helps establish the principle that a plaintiff must meet a standing requirement for each form of relief sought. Justice Marshall
Thurgood Marshall
Thurgood Marshall was an Associate Justice of the United States Supreme Court, serving from October 1967 until October 1991...
's dissent argued that the majority's test would immunize from review any widespread policy that deprives constitutional rights when individuals cannot show with certainty that they would be subject to a repeat violation. He also argued that the Court's traditional rule did not distinguish different forms of relief for standing purposes.