Alexander v. Sandoval

Supreme Court of the United States · 2001 · Torts

532 U.S. 275 (2001)

Updated July 23, 2026

implied private right of actionTitle VIadministrative regulationsstatutory interpretationSection 601Section 602implied cause of actionprivate remedy

Facts

The Alabama Department of Public Safety accepted federal financial assistance from DOJ and DOT, making it subject to Title VI. After Alabama amended its constitution to declare English the official language, the Department decided to administer driver's license examinations only in English. Sandoval sued on behalf of a class, alleging that the policy violated DOJ regulations issued under § 602 because it had the effect of discriminating based on national origin. The Supreme Court did not decide whether the regulation was valid or whether the policy in fact had a disparate impact, addressing only whether a private suit could enforce the regulation.

Issue

Does Title VI create a private cause of action allowing private individuals to enforce disparate-impact regulations promulgated by federal agencies under § 602? More specifically, may a private plaintiff sue to enforce regulations that prohibit conduct having a disparate impact when § 601 itself prohibits only intentional discrimination?

Rule

A private right of action exists only if Congress intended to create both a private right and a private remedy in the statutory text and structure. Title VI § 601 is privately enforceable, but § 602 does not display congressional intent to create a freestanding private right of action to enforce disparate-impact regulations; therefore, regulations may invoke a cause of action created by statute, but may not themselves create one.

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One of 10 multiple-choice questions for this case. Pick an answer to see why.

The Ohio Department of Workforce Services receives federal grant money from the Department of Justice. It adopts a residency-verification policy that uses facially neutral documentation rules and, according to a study, disproportionately excludes applicants of a particular national origin, though there is no evidence of purposeful bias.

A rejected applicant files suit in federal court seeking an injunction based solely on a federal agency regulation issued under a statute whose operative antidiscrimination provision bans only intentional discrimination, while a separate administrative section authorizes agencies to issue rules to effectuate that ban. What is the strongest argument for dismissal?

Explanation. The controlling rule is that private rights of action must be created by Congress. Even assuming the regulation is valid, a plaintiff cannot sue to enforce a regulation that prohibits conduct beyond the statute's own ban unless the statute itself shows congressional intent to create both a private right and a private remedy. A regulation may invoke a statutory cause of action, but it cannot create one on its own.