City of Los Angeles v. Lyons

City of Los Angeles v. Lyons

Supreme Court of the United States
Argued November 2, 1982
Decided April 20, 1983
Full case name City of Los Angeles v. Lyons
Citations 461 U.S. 95 (more)
103 S. Ct. 1660; 75 L. Ed. 2d 675; 51 U.S.L.W. 4424
Prior history 656 F.2d 417 (reversed)
Holding
A plaintiff must show a sufficiently plausible threat of future injury to possess standing to sue.
Court membership
Case opinions
Majority White, joined by Burger, Powell, Rehnquist, and O'Connor
Dissent Marshall, joined by Brennan, Blackmun, and Stevens

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.

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