In 1976, police officers of the City of Los Angeles stopped Adolph Lyons for a traffic code violation. Although Lyons offered no resistance, the officers, without provocation, seized Lyons and applied a chokehold. The hold rendered Lyons unconscious and damaged his larynx. Along with damages against the officers, Lyons sought an injunction against the City barring the use of such control holds.
Did Lyons's injunction against the use of police chokeholds meet the threshold requirements imposed by Article III of the Constitution?
No. In a 5-to-4 decision, the Court held that federal courts were without jurisdiction to entertain Lyons' claim for injunctive relief. The fact that Lyons had been choked once did nothing to establish "a real and immediate threat that he would again be stopped. . .by an officer who would illegally choke him into unconsciousness." The Court held that in order to establish an actual controversy, Lyons would have to show either 1) that all Los Angeles police officers always choked citizens with whom they had encounters, or 2) that the City ordered or authorized officers to act in such a manner. Lyons was thus limited to suing the police and the city for individual damages.
Decisions
Decision: 5 votes for Lyons, 4 vote(s) against Legal provision: Article 3, Section 2, Paragraph 1: Case or Controversy Requirement
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Full Opinion by Justice Byron R. White
