Rizzo v. Goode
Encyclopedia
Rizzo v. Goode, 423 U.S. 362 (1976), was United States Supreme Court case in which the Court held that a prophylactic injunction against non culpable state
executive officials
was an overbroad interference by the Federal Courts
in the state executive branches. In doing so, the court created a limit on the federal injunctive power in matters of state agency
internal affairs.
, charging that the police department had engaged in a "pervasive pattern of illegal and unconstitutional mistreatment by police officers." The Supreme Court cast the case as "a heated dispute between individual citizens and certain policemen ... [that] has evolved into an attempt by the federal judiciary to resolve a 'controversy' between the entire citizenry of Philadelphia and the petitioning elected and appointed officials over what steps might, in the Court of Appeals' words, '[appear] to have the potential for prevention of future police misconduct.'" The court - "express[ing] grave doubts about the justiciability" of the case - held that "the individual respondents' claim to 'real and immediate' injury rests not upon what the named petitioners might do to them in the future -- such as set a bond on the basis of race -- but upon what one of a small, unnamed minority of policemen might do to them in the future because of that unknown policeman's perception of departmental disciplinary procedures. This hypothesis is even more attenuated than those allegations of future injury found insufficient in O'Shea to warrant invocation of federal jurisdiction. Thus, insofar as the individual respondents were concerned, we think they lacked [standing]."
Moreover, "appropriate consideration must be given to principles of federalism in determining the availability and scope of equitable relief," the court said; "[w]here, as here, the exercise of authority by state officials is attacked, federal courts must be constantly mindful of the "special delicacy of the adjustment to be preserved between federal equitable power and State administration of its own law." In such a setting, "principles of equity ... militate heavily against the grant of an injunction except in the most extraordinary circumstances."
U.S. state
A U.S. state is any one of the 50 federated states of the United States of America that share sovereignty with the federal government. Because of this shared sovereignty, an American is a citizen both of the federal entity and of his or her state of domicile. Four states use the official title of...
executive officials
Executive officer
An executive officer is generally a person responsible for running an organization, although the exact nature of the role varies depending on the organization.-Administrative law:...
was an overbroad interference by the Federal Courts
United States federal courts
The United States federal courts make up the judiciary branch of federal government of the United States organized under the United States Constitution and laws of the federal government.-Categories:...
in the state executive branches. In doing so, the court created a limit on the federal injunctive power in matters of state agency
Government agency
A government or state agency is a permanent or semi-permanent organization in the machinery of government that is responsible for the oversight and administration of specific functions, such as an intelligence agency. There is a notable variety of agency types...
internal affairs.
Procedure and history
Plaintiffs sued a number of Philadelphia officials in a § 1983 suitCivil Rights Act of 1871
The Civil Rights Act of 1871, , enacted April 20, 1871, is a federal law in force in the United States. The Act was originally enacted a few years after the American Civil War, along with the 1870 Force Act. One of the chief reasons for its passage was to protect southern blacks from the Ku Klux...
, charging that the police department had engaged in a "pervasive pattern of illegal and unconstitutional mistreatment by police officers." The Supreme Court cast the case as "a heated dispute between individual citizens and certain policemen ... [that] has evolved into an attempt by the federal judiciary to resolve a 'controversy' between the entire citizenry of Philadelphia and the petitioning elected and appointed officials over what steps might, in the Court of Appeals' words, '[appear] to have the potential for prevention of future police misconduct.'" The court - "express[ing] grave doubts about the justiciability" of the case - held that "the individual respondents' claim to 'real and immediate' injury rests not upon what the named petitioners might do to them in the future -- such as set a bond on the basis of race -- but upon what one of a small, unnamed minority of policemen might do to them in the future because of that unknown policeman's perception of departmental disciplinary procedures. This hypothesis is even more attenuated than those allegations of future injury found insufficient in O'Shea to warrant invocation of federal jurisdiction. Thus, insofar as the individual respondents were concerned, we think they lacked [standing]."
Moreover, "appropriate consideration must be given to principles of federalism in determining the availability and scope of equitable relief," the court said; "[w]here, as here, the exercise of authority by state officials is attacked, federal courts must be constantly mindful of the "special delicacy of the adjustment to be preserved between federal equitable power and State administration of its own law." In such a setting, "principles of equity ... militate heavily against the grant of an injunction except in the most extraordinary circumstances."