Friday, February 1, 2013

City of Los Angeles v. Lyons case brief

City of Los Angeles v. Lyons case summary
461 U.S. 95

PROCEDURAL HISTORY: Petitioner municipality appealed an order of the United States Court of Appeals for the Ninth Circuit, which affirmed the issuance of a preliminary injunction requested by respondent and enjoined the municipality from using specified choke holds when apprehending suspects who did not threaten death or bodily injury.

FACTS: 
-Respondent, a motorist injured by the city police when subjected to a choke hold after being stopped for a traffic violation, argued that an injunction directed at the municipality was warranted to prevent respondent and others similarly situated from being threatened with injury in the future. 
-The Court disagreed, explaining that federal courts were without jurisdiction to entertain respondent's claim for injunctive relief.

HOLDING:
-The Court held that to invoke jurisdiction, respondent was required to show that he was in immediate danger of irreparable injury; neither the existence of past injury nor conjecture over the prospect of some future injury created the case or controversy required for jurisdiction.

ANALYSIS: 
-The Court stated, while respondent may have had a claim for damages based on the injury he already sustained, injunctive relief was not available absent a real and immediate likelihood that respondent would again be targeted by the municipality. 
-There was no showing, the Court concluded, that the municipality's revised policy on the use of choke holds would be applied indiscriminately and thereby result in injury to respondent or other citizens.

CONCLUSION: The Court reversed the lower court's order that had enjoined the municipality from applying choke holds when apprehending suspects who did not threaten death or bodily injury.
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