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City of Los Angeles v. Lyons
Citations: 449 U.S. 934; 101 S. Ct. 333; 66 L. Ed. 2d 158; 49 U.S.L.W. 3288; 1980 U.S. LEXIS 3654Docket: 79-1995
Court: Supreme Court of the United States; October 20, 1980; Federal Supreme Court; Federal Appellate Court
The Supreme Court of the United States denied a petition for a writ of certiorari in the case of City of Los Angeles v. Adolph Lyons, which was reviewed from the Ninth Circuit Court of Appeals. The Court granted the respondent's motion to proceed in forma pauperis. Justice White, joined by Justices Powell and Rehnquist, dissented from the decision to deny certiorari, questioning the respondent's standing to seek injunctive and declaratory relief under 42 U.S.C. § 1983 based on precedents set in O'Shea v. Littleton and Rizzo v. Goode. In February 1977, Lyons filed a seven-count complaint against the city and four police officers, alleging that the officers unlawfully applied strangleholds during a minor traffic stop, asserting this was a department policy. He claimed that such actions violated multiple constitutional amendments and sought damages and injunctive relief. The Court of Appeals ruled that Lyons had standing due to a higher likelihood of future encounters with the police, distinguishing his case from O'Shea and Rizzo by emphasizing that he was not seeking structural relief but rather an injunction to prevent specific practices. Justice White argued that past exposure to unlawful conduct without ongoing adverse effects does not constitute a case or controversy under Article III, and that any future harm Lyons might face is too abstract to establish standing. The dissent highlighted that, like in O'Shea, the potential for future injury does not meet the necessary criteria for equitable relief, making it unclear that Lyons had the required standing to pursue his claims. The dissenting opinion argues against the denial of certiorari, stating that the Court of Appeals' decision contradicts established precedents. It acknowledges that while the respondent could have challenged the police's actions due to standing, the court's analysis relies on mootness doctrine exceptions. The first exception, concerning voluntary cessation of conduct, is deemed insufficient because the potential harm to the respondent is generalized and not specific, raising doubts about standing. The second exception, addressing claims that are "capable of repetition, yet evading review," is also rejected as the constitutional issue can be adequately addressed through a damages action under Section 1983. Thus, the dissent emphasizes that if a valid cause of action exists under 1983, the constitutional questions would be resolved in that context.