Arizonans for Official English v. Arizona

Supreme Court of the United States · 1997 · Federal Courts

Federal CourtsArticle IIIStandingMootnessVacaturCertification of state-law questionscase or controversystanding to appeal

Facts

Arizona adopted a constitutional amendment making English the official language of the State and providing that, with specified exceptions, the State shall act in English and in no other language. Maria-Kelly F. Yniguez, then a state employee who used both English and Spanish in her work, sued under 42 U.S.C. § 1983 for declaratory and injunctive relief, alleging the amendment violated the Federal Constitution. She sued only as an individual, not as a class representative, and later left state employment for a private-sector job. After her departure, the Ninth Circuit treated her complaint as supporting nominal damages and continued to adjudicate the amendment's constitutionality.

Issue

Whether a live Article III case or controversy remained after Yniguez left state employment, and, if not, whether the Ninth Circuit's merits judgment should be vacated. The Court also considered whether initiative proponents had standing to defend the measure on appeal, but declined to decide that question definitively.

Rule

Federal courts may not adjudicate challenges to state measures without a showing of actual impact on the challenger, and an actual controversy must remain extant at all stages of review. A moot case cannot be revived by a nonexistent claim for nominal damages, and when a civil case becomes moot pending appellate adjudication, the established practice is to vacate the judgment below and remand with directions to dismiss.

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

Nina Alvarez worked for the Colorado Department of Licensing in Denver and sued state officials under 42 U.S.C. § 1983, seeking only declaratory and injunctive relief against a newly adopted workplace communications rule she claimed restricted her speech on the job. While the state's appeal was pending, Nina voluntarily resigned and took a job with a private insurance firm in Boulder, and she did not allege any plan to return to state employment.

What is the strongest Article III argument about the status of Nina's case on appeal?

Explanation. Article III requires an actual controversy at all stages of review, not just when suit is filed. A plaintiff who sought only prospective relief against restrictions governing her state employment loses the necessary continuing stake once she voluntarily leaves that employment and is no longer regulated by the rule. The fact that the district court already ruled on the merits does not preserve jurisdiction. (Derived from Arizonans for Official English v. Arizona (1997).)