| Rizzo v. Goode | ||||||
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Supreme Court of the United States |
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| Argued November 11, 1975 Decided January 21, 1976 |
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| Full case name | Rizzo, Mayor of Philadelphia, et al. v. Goode, et al. | |||||
| Citations | 423 U.S. 362 (more) 96 S. Ct. 598; 46 L. Ed. 2d 561; 1976 U.S. LEXIS 42 |
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| Court membership | ||||||
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| Case opinions | ||||||
| Majority | Rehnquist, joined by Burger, Stewart, White, Powell | |||||
| Dissent | Blackmun, joined by Brennan, Marshall | |||||
| Stevens took no part in the consideration or decision of the case. | ||||||
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.[1]
Plaintiffs sued a number of Philadelphia officials in a § 1983 suit, charging that the police department had engaged in a "pervasive pattern of illegal and unconstitutional mistreatment by police officers."[2] 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.'"[3] The court - "express[ing] grave doubts about the justiciability" of the case[4] - 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]."[5]
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."[6] In such a setting, "principles of equity ... militate heavily against the grant of an injunction except in the most extraordinary circumstances."[7]