O'Shea v. Littleton, 414 U.S. 488 (1974)
A federal court may assume jurisdiction over a case only when the party bringing it can allege a threatened or actual injury that arises from a putatively illegal action.
Littleton claimed that his rights under the First, Sixth, Eighth, Thirteenth, and Fourteenth Amendments had been violated by discriminatory practices in the criminal justice system of Alexander County, Illinois. He brought an action against O'Shea, the States Attorney for the County, under 42 U.S.C. Section 1983 and related federal laws. Some of the statements in the complaint were based on alleged discrimination by O'Shea against African-Americans and poor people, such as applying criminal laws and procedures more harshly against these groups while applying them too leniently to whites who attacked African-Americans. Littleton argued that O'Shea engaged in these practices to prevent African-Americans from lawfully seeking to attain equality.
The lower court held that it lacked jurisdiction to hear the case or issue the injunction that Littleton sought. It also ruled that O'Shea was protected by governmental immunity for actions in his official capacity. The intermediate appellate court disagreed and held that an injunction could be granted against O'Shea if Littleton could show that he had knowingly engaged in racially discriminatory conduct against a cognizable group.
- Byron Raymond White (Author)
- Warren Earl Burger
- Potter Stewart
- Lewis Franklin Powell, Jr.
- William Hubbs Rehnquist
There is no actual case or controversy requirement here, so the complaint fails the threshold requirements of Article III. Only an abstract form of harm is stated, and there is no allegation that the plaintiff has suffered or is about to suffer a direct injury because of the action taken by the defendant. The injunction sought by the plaintiff is intended only to prevent future harm that might possibly occur in the state criminal justice system, but this is too speculative to meet the Article III requirements for seeking an equitable remedy. Instead, the plaintiff would need to show a likelihood of substantial and immediate irreparable injury, as well as proving that legal remedies like damages would be inadequate. A valid cause of action could arise if the plaintiff eventually were prosecuted and subjected to a trial, or if he were improperly convicted.
- Harry Andrew Blackmun (Author)
The case or controversy requirement in Article III is not satisfied here.
- William Orville Douglas (Author)
- William Joseph Brennan, Jr.
- Thurgood Marshall
While the complaint does not specifically outline the sources of proof that the plaintiff will use, the allegations regarding past and continuing conduct are sufficiently specific to state a case or controversy in a way that meets the Article III requirements.Case Commentary
Cases involving official law enforcement procedures often cannot be clearly connected to a particular victim who will be harmed by the implementation of those policies in the future. Structural relief often is the remedy that is pursued, which is a way of trying to ensure that the government complies with certain rules in conducting its affairs. Justiciability doctrines like ripeness and standing have been used by courts to stay aloof from these issues.
U.S. Supreme CourtO'Shea v. Littleton, 414 U.S. 488 (1974)
O'Shea v. Littleton
Argued October 17, 1973
Decided January 15, 1974
414 U.S. 488
Respondents, 17 black and two white residents of Cairo, Illinois, brought a civil rights class action against petitioners, a magistrate and a circuit court judge, who allegedly engaged under color of state law, in a continuing pattern and practice of conduct consisting of illegal bond-setting, sentencing, and jury fee practices in criminal cases, which assertedly deprived respondents and members of their class of their rights under the Constitution and 42 U.S.C. §§ 1981-1983, 1985. The District Court dismissed the action for want of jurisdiction to issue the injunctive relief sought and on the ground of judicial immunity. The Court of Appeals reversed, holding that issuance of injunctions against judicial officers was not forbidden if their conduct was intentionally racially discriminatory against a cognizable class of persons. Absent sufficient remedy at law, it was held that, if respondents proved their allegations, the District Court should fashion appropriate relief to enjoin petitioners from depriving others of their constitutional rights while carrying out their judicial duties in the future.
1. The complaint fails to satisfy the threshold requirement of Art. III of the Constitution that those who seek to invoke the power of federal courts must allege an actual case or controversy where none of the named plaintiffs is identified as himself having suffered any injury in the manner specified, the claim alleging injury is in only the most general terms, and there are no allegations that any relevant state criminal statute is unconstitutional on its face or as applied or that plaintiffs have been or will be improperly charged with violating criminal law. Pp. 414 U. S. 493-499.
(a) If none of the named plaintiffs purporting to represent a class meets the case or controversy requirement, none may seek relief on behalf of himself or any other member of the class. Pp. 414 U. S. 494-495.
(b) That requirement is not satisfied by general assertions or inferences that, in the course of their activities, respondents will be prosecuted for violating valid criminal laws. P. 414 U. S. 497.
(c) Where it can only be speculated whether respondents will be arrested for violating an ordinance or state statute, particularly in the absence of allegations that unconstitutional criminal statutes are being employed to deter constitutionally protected conduct, and respondents have not pointed to any imminent prosecutions contemplated against them so that they do not claim any constitutional right to engage in conduct proscribed by therefore presumably permissible state laws, or that it is otherwise their intention to so conduct themselves, the threat of injury from the alleged course of conduct they attack is too remote to satisfy the case or controversy requirement and permit adjudication by a federal court. Pp. 414 U. S. 497-498.
2. Even if the complaint were considered to present an existing case or controversy, no adequate basis for equitable relief has been stated. Pp. 414 U. S. 499-504.
(a) The injunctive relief sought by respondents would constitute a ma, or continuing intrusion of the equitable power of the federal courts into the daily conduct of state criminal proceedings, and would sharply conflict with recognized principles of equitable restraint, Younger v. Harris, 401 U. S. 37. Pp. 414 U. S. 499-502.
(b) Respondents also failed to establish the basic requisites of the issuance of equitable relief -- the likelihood of substantial and immediate irreparable injury, and the inadequacy of remedies at law -- in view of the conjectural nature of the threatened injury to which respondents are allegedly subjected, and where there are available other procedures, both state and federal, which could provide relief. Pp. 414 U. S. 502-504.
468 F.2d 389, reversed.
WHITE, J., delivered the opinion of the Court, in which BURGER, C.J., and STEWART, POWELL, and REHNQUIST, JJ., joined. BLACKMUN, J., filed an opinion concurring in the judgment and in Part I of the Court's opinion, post, p. 414 U. S. 504. DOUGLAS, J., filed a dissenting opinion, in which BRENNAN and MARSHALL, JJ., joined, post, p. 414 U. S. 505.