City of Los Angeles vs.

Lyons, 461 US 95
FACTS:
In 1976, Adolph Lyons was stopped by the officers for a traffic violation, and
that, although he offered no resistance, the officers, without provocation or
justification, seized him and applied a "chokehold," rendering him
unconscious and causing damage to his larynx.
In addition to seeking damages, it was alleged that police officers routinely
applied chokeholds in situations where they were not threatened by the use
of any deadly force and that numerous persons had been injured as a result.
The District Court entered such an injunction. The Court of Appeals for the
Ninth Circuit affirmed. The municipality appealed to the Supreme Court.
ISSUES:
Does this case present an actual case or controversy that can be
determined by the Supreme Court? If so, does Lyons have standing to seek
injunctive relief against the municipality of Los Angeles?
HELD:
The Court reversed the lower court's order that had enjoined the municipality
from applying choke holds when apprehending suspects who did not threaten
death or bodily injury.
This case does not present an actual case or controversy as required in the
Constitution under Article III. Past illegal conduct, by itself, is insufficient to
establish an actual case or controversy for injunctive relief. Even though
Lyons was injured by the police in the past, this act alone does not establish
that Lyons is threatened with immediate injury or that he will be pulled over
and placed in a chokehold again.
There was no showing, the Court concluded, that the municipality's revised
policy on the use of choke holds would be applied indiscriminately and
thereby result in injury to respondent or other citizens.