DeFunis v. Odegaard

40 L. Ed. 2d 164 · Supreme Court of the United States · 1974

Facts

Marco DeFunis, Jr. applied for admission to the University of Washington Law School in 1971, which had 150 spots for 1,600 applicants. He was denied admission. DeFunis then sued the University, contending that the Law School's admissions procedures and criteria invidiously discriminated against him on account of his race, violating the Equal Protection Clause of the Fourteenth Amendment. He sought a mandatory injunction to compel his admission to the first-year class.

Procedural history

DeFunis commenced suit in a Washington trial court, which agreed with his claim and granted the requested relief, admitting him to the Law School. On appeal, the Washington Supreme Court reversed the trial court's judgment, holding the Law School admissions policy constitutional. DeFunis then petitioned the U.S. Supreme Court for a writ of certiorari, and a stay was granted, allowing him to remain in law school. The Supreme Court granted certiorari and heard oral arguments.

Issue

Does a case challenging a law school's admissions policy become moot when the petitioner, who was admitted by court order, is in the final quarter of his final year of law school and assured of graduation regardless of the Supreme Court's decision on the merits?

Holding

Yes, the case is moot because the petitioner will complete his law school studies and receive his degree regardless of the Court's decision, meaning there is no longer a live case or controversy.

Rule

Federal courts are without power to decide questions that cannot affect the rights of litigants, as required by the "case or controversy" clause of Article III of the Constitution. A controversy ceases to be "definite and concrete" and no longer "touches the legal relations of parties having adverse legal interests" when the requested remedy has been fully accorded and the outcome of the litigation cannot change the parties' status. The "capable of repetition, yet evading review" exception does not apply if the issue is not capable of repetition for the specific litigant and future cases on the issue are likely to reach the court.

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