532 U.S. 275, 121 S. Ct. 1511, 149 L. Ed. 2d 517
In 1990, the State of Alabama amended its Constitution to declare English the official language of the state and enacted a statute providing that driver’s license examinations shall be given in English only.1 The Alabama Department of Public Safety accepted grants of financial assistance from the United States Department of Justice and Department of Transportation and implemented an English-only policy for its driver’s license examinations.2
Respondent Sandoval, a Spanish-speaking resident of Alabama who is not fluent in English, applied for a driver’s license but was unable to take the examination because of the policy.3 Sandoval brought suit in the United States District Court for the Middle District of Alabama against petitioner James Alexander, the Director of the Department of Public Safety, and other state officials.4 She alleged that the English-only policy violated Title VI of the Civil Rights Act of 1964 and the regulations promulgated thereunder by the Department of Justice.5 Sandoval sought to enjoin the policy and to require the State to administer the examination in Spanish.6
The District Court certified a class of all non-English-speaking persons in the State who have been or will be denied the opportunity to take the driver’s license examination because of the English-only policy.7 The District Court granted summary judgment in favor of the class.8 It held that the English-only policy violated the Department of Justice’s regulation implementing Title VI, which forbids recipients of federal funding from utilizing criteria or methods of administration which have the effect of subjecting individuals to discrimination because of their race, color, or national origin.9 The court rejected the State’s argument that Title VI does not provide a private cause of action to enforce the regulation.10 It entered an injunction requiring the State to administer the driver’s license examination in Spanish to members of the class.11
The Court of Appeals for the Eleventh Circuit affirmed the District Court’s judgment.12 It held that Title VI’s implementing regulations may be enforced in a private action under 42 U.S.C. §1983 and that the regulation at issue was valid.13 Petitioners sought review in the Supreme Court of the United States, which granted certiorari to resolve a conflict among the Courts of Appeals on the question whether Title VI’s regulations may be enforced in a private action.14
Whether private individuals may sue to enforce regulations promulgated under §602 of Title VI of the Civil Rights Act of 1964?15
Congressional intent, as revealed by the text and structure of the statute, determines whether a private right of action exists; §601 creates a private right to enforce its prohibition on intentional discrimination, but §602's authorization for disparate-impact regulations does not create such a right.16
No. The ESTABLISHED FACTS establish that Sandoval brought suit to enforce the Department of Justice regulation under Title VI that prohibits criteria or methods of administration with the effect of discriminating on the basis of national origin. The English-only policy was challenged as having such a disparate impact.17 However, the regulation does not simply apply section 601 but goes beyond it to prohibit conduct that section 601 permits, and the text of section 602 is phrased as a directive to federal agencies rather than as creating rights for individuals.18
Private individuals may not sue to enforce the regulations promulgated under §602.19
Related opinions on this issue
Joined by Justices Souter, Ginsburg, And Breyer
Justice Stevens, joined by Justices Souter, Ginsburg, and Breyer, dissented. He argued that the Court's prior decisions in Lau, Cannon, and Guardians already established that private parties may enforce Title VI regulations, including those prohibiting disparate impact.20 Stevens contended that the majority's limitation of Cannon to intentional discrimination cases was unfounded because Cannon itself involved a disparate impact claim and the holding applied to all prohibited discrimination.21
He further maintained that the regulations are an integral part of the statutory scheme and that the majority's approach undermines settled expectations and congressional intent.22
Whether the regulations may be enforced in an action under 42 U.S.C. §1983?23
Section 1983 provides a cause of action only for violations of federal statutes that create enforceable rights; regulations that do not create rights may not be enforced through section 1983.24
No. Although the Eleventh Circuit held that Title VI’s implementing regulations could be enforced in a private action under section 1983 against Alabama officials enforcing the English-only driver’s license policy, the regulations do not create enforceable rights. They go beyond the statute's core prohibition on intentional discrimination by reaching disparate-impact discrimination that section 601 permits, and therefore may not be enforced through section 1983 under the standards of Suter v. Artist M. and Blessing v. Freestone.25
The regulations may not be enforced in an action under 42 U.S.C. §1983.26
Whether a private litigant may enforce the regulations through an action for injunctive relief under the court’s equitable powers?27
Courts will not imply a private right of action for injunctive relief where Congress has not intended one; equitable powers do not create a remedy absent statutory authorization.28
No. Sandoval, as class representative, obtained an injunction from the district court enforcing the disparate-impact regulation against Alabama's English-only driver's license policy.29 The text and structure of Title VI demonstrate that Congress did not intend to create a private right of action to enforce the §602 regulations.30 Equitable relief is therefore unavailable because the statute focuses on directives to federal agencies rather than on creating individual rights enforceable by private litigants.31
A private litigant may not enforce the regulations through an action for injunctive relief under the court’s equitable powers.32