Supreme Court of the United States
City of Los Angeles v. Lyons
April 20, 1983461 U.S. 95
Summary
The Court held that Lyons lacked standing to seek an injunction against Los Angeles's use of police chokeholds because he did not show a real and immediate likelihood that he would again be stopped and subjected to an unconstitutional chokehold. His prior injury supported a damages claim but did not establish the future injury or irreparable harm required for prospective equitable relief. The judgment reversing the preliminary injunction was therefore reversed.
Holding
- Article III standing to seek injunctive relief. Lyons lacked standing to seek an injunction because his past choking did not establish a real and immediate threat that he would again be stopped and subjected to an unlawful chokehold. The allegations required speculation that he would encounter the police again and that the encounter would result in an unprovoked chokehold.
- Availability of equitable relief. The injunction was unavailable because Lyons failed to show a likelihood of substantial and immediate irreparable injury, and his past injury was remediable through damages. Section 1983 did not eliminate the ordinary equitable requirements or the need for federal courts to exercise restraint when overseeing state and local law-enforcement authorities.
Docket 81-1064
Cited authorities
- Rule 54(c) of the Federal Rules of Civil Procedure
- Rule 54(c)
- 42 U.S.C. § 1983
- 28 U.S.C. § 2283
- 42 U.S.C. § 1983
- 42 U.S.C. § 1983
- 42 U.S.C. § 1983
- 28 U.S.C. § 2283
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