City of Los Angeles v. Lyons

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City of Los Angeles v. Lyons
Seal of the United States Supreme Court.svg
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 Reversed, 656 F.2d 417
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, O'Connor
Dissent Marshall, joined by Brennan, Blackmun, Stevens
Laws applied
U.S. Const. Art. III

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.


Adolph Lyons, an African American man, 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 [1]).

Opinion of the Court[edit]

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 helped 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.[2] He also argued that the Court's traditional rule did not distinguish different forms of relief for standing purposes.

Analysis and commentary[edit]

Based on Michelle Alexander’s book, The New Jim Crow, Adolph Lyons' case is related to what is believed to be biased action towards certain races, in this case African Americans. She asserts that it is hard for people of color like Lyons to prevail in the judicial process, similar to what happened during the Jim Crow era. According to Alexander, one of the causes of such issues is the presence of implicit bias in the criminal justice system, including the courts and police officers. In support of Alexander's argument, Georgetown Law provides Professor Charles Lawrence noted, "The purposeful intent requirement found in Supreme Court equal protection doctrine, and in the court's interpretation of antidiscrimination laws disserved the value of equal citizenship expressed in those laws because many forms of racial bias are unconscious."[3] As specified above, since Lyons' case involves legal system, unconscious bias may produce negative outcomes for African Americans.[4][5]

See also[edit]


  1. ^ Millhiser, Ian (4 Dec 2014). "How The Supreme Court Helped Make It Possible For Police To Kill By Chokehold". ThinkProgress. Retrieved 12 Dec 2014. 
  2. ^ Gilson, Dave (4 Dec 2014). "Thurgood Marshall Blasted Police for Killing Black Men With Chokeholds". Mother Jones. Retrieved 12 Dec 2014. 
  3. ^ Lawrence, Charles R. III (2008). "Unconscious Racism Revisited: Reflections on the Impact and Origins of "The Id, the Ego, and Equal Protection". 
  4. ^ The New Jim Crow: Mass Incarceration in the Age of Colorblindness, Michelle Alexander, The New Press, New York 2010, ISBN 978-1-59558-103-7
  5. ^ The New Jim Crow, p. 128-129

External links[edit]

  • Text of City of Los Angeles v. Lyons, 461 U.S. 95 (1982) is available from:  Findlaw  Justia 
  • Ronald T. Gerwatowski, Standing and Injunctions: The Demise of Public Law Litigation and Other Effects of Lyons, Boston College Law Review, vol 25 p 765 (1984),