Law School Case Brief
Texas v. United States - 523 U.S. 296, 118 S. Ct. 1257 (1998)
A claim is not ripe for adjudication if it rests upon contingent future events that may not occur as anticipated, or indeed may not occur at all.
The Texas Legislature enacted a comprehensive scheme that held local school boards accountable to the state for student achievement. The scheme provided for sanctions against those districts that did not achieve the legislative goals. Because Texas was a covered jurisdiction under § 5 of the Voting Rights Act, 42 U.S.C.S. § 1973c, it was required to obtain preclearance from the district court or the United States Attorney General. The Attorney General concluded that six of the sanctions did not affect voting and did not need preclearance but cautioned that two of the sanctions could result in violation of § 5 and thus would require preclearance. Plaintiff State of Texas filed an action in federal district court seeking a declaration that the two sanctions did not require preclearance. A three-judge panel of the district court concluded that Texas' claim was not ripe for adjudication, and thus granted the United States' motion to dismiss without reaching the merits of the case. Texas appealed.
Taking into consideration the circumstances of the case at hand, was Texas' claim ripe for adjudication?
The Supreme Court of the United States held that the claim was not ripe for adjudication because whether Texas would ever appoint a master or management team as a sanction was contingent on a number of factors. The Court averred that legislation in advance of its immediate adverse effect involved too remote and abstract an inquiry for the proper exercise of judicial review.
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