DeFunis v. Odegaard

Supreme Court of the United States · 1974 · Constitutional Law

416 U.S. 312 (1974)

Updated July 29, 2026

Constitutional LawMootnessArticle IIICase or Controversylaw school admissionsinjunctionvacaturvoluntary cessation

Facts

In 1971 Marco DeFunis, Jr. applied to the University of Washington Law School and was denied admission. He sued only on his own behalf, alleging that the Law School's admissions procedures discriminated against him because of his race, and he sought only a mandatory injunction ordering his admission. The trial court granted that relief, and DeFunis entered the Law School; after the Washington Supreme Court reversed, a stay allowed him to remain enrolled. By the time the case was before the U.S. Supreme Court, DeFunis had registered for the final quarter of his final year, and the Law School represented that it would not seek to cancel that registration and that he could complete his studies and receive his degree regardless of the Court's merits decision.

Issue

Whether DeFunis' challenge to the Law School's admissions policy remained a live Article III case or controversy when he had already been admitted, had registered for the final term of his final year, and the Law School represented that he would be allowed to complete his studies and receive his degree regardless of the Court's decision.

Rule

Federal courts lack power under Article III to decide questions that cannot affect the rights of the litigants before them. A case is moot when the controversy has ceased to be definite and concrete and no effective relief remains available; neither the voluntary cessation doctrine nor the capable-of-repetition-yet-evading-review exception applies where mootness rests on the plaintiff's impending completion of the challenged course of study and the plaintiff will not again be subjected to the challenged process.

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

Nina Patel sued a public dental school in Michigan seeking only an injunction requiring her admission. A state trial court ordered the school to admit her pending review, and by the time her case reached the U.S. Supreme Court she had enrolled in her final semester; the school, through the state attorney general, formally represented that her registration would remain effective and that she would receive her degree if she completed the requirements regardless of the Court's ruling.

Should the Court dismiss Nina's case as moot?

Explanation. A federal court lacks power to decide questions that cannot affect the rights of the litigants before it. Where the plaintiff sued only on her own behalf and sought only admission, and she is guaranteed completion of her final term and degree regardless of the merits outcome, no effective relief remains available. The ongoing existence of the policy for others does not preserve this plaintiff's individual case.