Adler v. Duval Cty. Sch. Bd. - 112 F.3d 1475 (11th Cir. 1997)

Rule:

U.S. Const. art. III, § 2 limits the jurisdiction of the federal courts to the consideration of certain cases and controversies. The doctrine of mootness is derived from this limitation because an action that is moot cannot be characterized as an active case or controversy. A case is moot when the issues presented are no longer "live" or the parties lack a legally cognizable interest in the outcome. Any decision on the merits of a moot case would be an impermissible advisory opinion. 

Facts:

Appellants are four former high school students in the Duval County, Florida, school system who brought this action under 42 U.S.C. § 1983 (1994), alleging that a Duval County school policy permitting student-initiated prayer at high school graduation ceremonies (the "policy") violated their rights under the First and Fourteenth Amendments. They named as defendants the Duval County School Board, the Board's members in their official capacity, the Duval County School District, and Dalton Epting, the principal of Mandarin Senior High School, in his official capacity. Appellants asked for equitable relief in the form of a judgment declaring the policy unconstitutional and enjoining the School Board from permitting prayers at high school graduation ceremonies. They also sought money damages. The defendants filed cross-motions for summary judgment. The district court denied the appellants' motion and granted the appellees' motions. In its dispositive memorandum opinion and order, the court found the policy constitutional and entered final judgment for the appellees. Adler, 851 F. Supp. at 456. Appellants appealed.

Issue:

Did the former students have a legally cognizable need for relief declaring the policy unconstitutional and preventing the School Board from allowing prayers at future graduations?

Answer:

No.

Conclusion:

The court concluded that the case was moot because appellants were all former students who would not again be subjected to graduation ceremonies. Therefore, the court vacated the summary judgment for appellees on the equitable claims, and remanded the case with instructions to dismiss. The court affirmed the denial of appellants' motion for summary judgment on their claims for monetary damages because the court found that appellants waived any claim to monetary damages. Similarly, the court affirmed the grant of appellees' motion for summary judgment on the monetary issues.