Alvarez v. Smith

Supreme Court of the United States · 2007 · Federal Courts

Federal CourtsMootnessVacaturArticle III Case or ControversymootnessvacaturArticle IIIcases or controversies

Facts

Illinois law permits warrantless seizure of cars and cash used to facilitate drug crimes and allows the State up to 142 days, nearly five months, before beginning judicial forfeiture proceedings. Six individuals whose cars or cash had been seized without warrants sued under §1983, seeking declaratory and injunctive relief requiring a prompt postseizure hearing. While the case was pending, the State returned all seized cars, and the cash disputes were resolved either by default or by agreement. At oral argument, both sides confirmed there was no longer any dispute over ownership or possession of the property.

Issue

Whether the case remained a live Article III controversy after all underlying disputes over the seized cars and cash had been resolved, and if not, whether the Court should vacate the Seventh Circuit's judgment.

Rule

An actual controversy must exist at all stages of review, not just when the complaint is filed; when only an abstract dispute about the law remains and no live dispute over the parties' concrete rights persists, the case is moot. In a moot case, the Court normally vacates the lower court judgment, but may deny vacatur when mootness results from settlement rather than happenstance.

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

Nina Patel filed a §1983 action in federal court in Phoenix seeking only a declaration and injunction requiring faster post-seizure hearings after local officers took her motorcycle under a state forfeiture statute. While the case was pending on appeal, the county returned the motorcycle and dismissed the forfeiture proceeding, and no other relief was requested in the operative complaint.

If the court of appeals asks whether it still has Article III jurisdiction, what is the best answer?

Explanation. An actual controversy must exist at all stages of review, not merely when the complaint is filed. Once Nina received the motorcycle back and her operative complaint sought only declaratory and injunctive relief, no concrete dispute remained over her rights to the property. What remains is only an abstract dispute about the law, which is insufficient under Article III. (Derived from Alvarez v. Smith (2007).)