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Watson v. Newark - 746 F.2d 1008 (3d Cir. 1984)

Rule:

An appellant must be privy to the record and must be aggrieved by the order appealed from. A party who receives all of the relief which he sought is not aggrieved by the judgment affording the relief and cannot appeal from it.

Facts:

Ronald E. Watson, Ronald Anderson and Dixie D. Wilson, employees of the City of Newark, Delaware, complained about the language in Newark, N.J., Charter § 1104, which prohibited city employees from taking part in political campaigns for public offices in the city. The employees sought declaratory and injunctive relief and alleged deprivation of their civil rights. The district court enjoined the city from enforcing the provision, only as it prohibited any city employee from taking part in any political campaigns for city government offices. On appeal, the employees alleged again their argument that the First Amendment did not allow restrictions on the political rights of employees of nonpartisan cities.

Issue:

Notwithstanding the fact that the district court has already granted an injunction in favor of the employees, can the latter still appeal the decision based on First Amendment grounds?

Answer:

No.

Conclusion:

The U.S. Circuit Court of Appeals dismissed the appeal for lack of standing because the employees got exactly what they asked for at the district court level, which was an injunction. Therefore, the Court held that employees could not appeal from a judgment affording the relief sought. The Court noted that, if the city enacted regulations that constituted an unconstitutional restriction upon their U.S. Const. Amend. I rights, in the employees' opinion, they could always bring an action at that time.

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