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DeFunis v. Odegaard
Citations: 40 L. Ed. 2d 164; 94 S. Ct. 1704; 416 U.S. 312; 1974 U.S. LEXIS 128Docket: 73-235
Court: Supreme Court of the United States; April 23, 1974; Federal Supreme Court; Federal Appellate Court
In 1971, Marco DeFunis, Jr. applied for admission to the University of Washington Law School, which had 150 spots available out of 1,600 applications. After being denied admission, he filed a lawsuit in a Washington trial court claiming that the Law School's admissions policies discriminated against him based on race, violating the Equal Protection Clause of the Fourteenth Amendment. DeFunis sought a mandatory injunction to compel his admission, and the trial court ruled in his favor. He was subsequently admitted and began his studies in fall 1971. However, the Washington Supreme Court reversed this decision, finding the admissions policy constitutional, while DeFunis was already in his second year. He petitioned the U.S. Supreme Court for a writ of certiorari, which resulted in a stay of the Washington Supreme Court's judgment, allowing him to continue his studies. By fall 1973, concerns arose regarding the potential mootness of the case as DeFunis was in his third year. Both parties argued that it was not moot, with the respondents noting that a favorable ruling could affect his ability to continue in future terms. The U.S. Supreme Court granted certiorari on November 19, 1973, and during oral arguments on February 26, 1974, it was confirmed that DeFunis had registered for his final quarter. The Law School assured that his registration would not be challenged, raising the question of mootness once more. Federal courts lack the authority to address issues that do not affect the rights of the parties involved, as established by Article III of the Constitution, which necessitates the existence of a case or controversy. Although Washington state law may allow for cases of great public interest to avoid mootness, mootness is ultimately a federal question that must be resolved before a federal court can assert jurisdiction. In the current case, the respondents confirmed that DeFunis will remain a student at the Law School for his enrolled term, allowing him to complete his studies and graduate, regardless of the Court's decision on the case's merits. All parties acknowledge that DeFunis is entitled to graduate, making any legal determination unnecessary. DeFunis did not file a class action suit, and the sole remedy sought was an injunction for his admission, which he has already received. The case has lost its concrete controversy as it no longer affects the legal relations of the parties. Even if the Law School’s policy changes contributed to the current situation, the respondents have assured that DeFunis's status will not be influenced by the Court's opinion on the matter. Previous cases indicate that voluntary cessation of alleged illegal conduct does not render a case moot, a principle that would be applicable if mootness had arisen from changes in the Law School's admission procedures. The litigation primarily targets the admissions procedures of the Law School, and any voluntary cessation of these practices could render the case moot only if there is no reasonable expectation of their recurrence. However, mootness in this instance hinges on the fact that DeFunis is nearing graduation and the Law School's established policy allows him to complete his current term. Although the case raises issues that might repeat yet evade review, it is not applicable to DeFunis since he will not undergo the admissions process again. The timing of the case's arrival in court, coinciding with his graduation, does not imply future issues will be similarly delayed. If the admissions practices remain unchanged, it is likely that future challenges will reach the Court expeditiously. Consequently, the case does not present an exceptional scenario allowing for deviation from the requirement of an actual controversy during appellate review. Given that DeFunis will complete his studies regardless of the Court's decision, substantive constitutional issues cannot be addressed under Article III of the Constitution. The judgment of the Supreme Court of Washington is therefore vacated, and the case is remanded for further proceedings. Additionally, while respondents acknowledge changes in admissions procedures, they confirm that these do not alter the challenged policy regarding special considerations for certain ethnic groups. Dissenting opinions suggest potential unforeseen circumstances could impede DeFunis’s graduation; however, such contingencies are deemed speculative and insufficient to warrant consideration of the substantive issues.