Law School Case Brief
O'Shea v. Littleton - 414 U.S. 488, 94 S. Ct. 669 (1974)
Plaintiffs in the federal courts must allege some threatened or actual injury resulting from the putatively illegal action before a federal court may assume jurisdiction. There must be a personal stake in the outcome such as to assure that concrete adverseness which sharpens the presentation of issues upon which the court so largely depends for illumination of difficult constitutional questions. Nor is the principle different where statutory issues are raised. Abstract injury is not enough. It must be alleged that the plaintiff has sustained or is immediately in danger of sustaining some direct injury as the result of the challenged statute or official conduct. The injury or threat of injury must be both "real and immediate," not "conjectural" or "hypothetical." Moreover, if none of the named plaintiffs purporting to represent a class establishes the requisite of a case or controversy with the defendants, none may seek relief on behalf of himself or any other member of the class.
The respondents are 19 named individuals who commenced this civil rights action, individually and on behalf of a class of citizens of the city of Cairo, Illinois, against the State's Attorney for Alexander County, Illinois, his investigator, the Police Commissioner of Cairo, and the petitioners here, Michael O'Shea and Dorothy Spomer, Magistrate and Associate Judge of the Alexander County Circuit Court (O’Shea), respectively, alleging that they have intentionally engaged in, and are continuing to engage in, various patterns and practices of conduct in the administration of the criminal justice system in Alexander County that deprive respondents of their constitutional rights secured by the First, Sixth, Eighth, Thirteenth, and Fourteenth Amendments, and by 42 U. S. C. §§ 1981, 1982, 1983, and 1985. The complaint, as amended, alleged that since the early 1960's, black citizens of Cairo, together with a small number of white persons on their behalf, have been actively, peaceably and lawfully seeking equality of opportunity and treatment in employment, housing, education, participation in governmental decision-making and in ordinary day-to-day relations with white citizens and officials of Cairo, and have, as an important part of their protest, participated in, and encouraged others to participate in, an economic boycott of city merchants who respondents consider have engaged in racial discrimination. Allegedly, there had resulted a great deal of tension and antagonism among the white citizens and officials of Cairo. The District Court dismissed the case for want of jurisdiction to issue the injunctive relief prayed for and on the ground that O’Shea were immune from suit for their official acts. On appeal, the United States Court of Appeals for the Seventh Circuit reversed, holding that if the plaintiffs proved their allegations, appropriate injunctive relief should be granted. However, the Supreme Court reversed the appellate court judgment that held that the issuance of an injunction was not forbidden and that directed the lower court to fashion appropriate injunctive relief.
Did the court have jurisdiction over the case?
The Supreme Court of the United States held that the complaint failed to satisfy the threshold requirement imposed by U.S. Const. art. III that those who seek to invoke the power of federal courts must allege an actual case or controversy. None of respondents claimed they suffered any injury in the manner specified, and the case or controversy requirement was not satisfied by general assertions that respondents would be prosecuted for violating valid criminal laws. Moreover, respondents did not establish likelihood of substantial and immediate irreparable injury and inadequacy of remedies at law.
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