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Alexander v. Sandoval

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Bloomberg Law

Citation. 532 U.S. 275, 121 S. Ct. 1511, 149 L. Ed. 2d 517 (2001)

Facts.Petitioner, James Alexander (the "Petitioner"), was the director of Alabama's Department of Public Safety (the "Department"). The Department received grants of financial assistance from both the United States Department of Justice ("DOJ") and United States Department of Transportation. As such, the Department was subject to Title VI of the Civil Rights Act of 1964 ("Title VI"). Section 601 of Title VI states, no person shall, "on the ground of race, color, or national origin, be excluded from   participation in, be denied the benefits of, or be subjected to discrimination under any program or activity". Section 602 allowed federal agencies to promulgate regulations to "effectuate the provisions" of §601. The DOJ adopted a regulation forbidding recipients of funding from "utilize[ing] criteria or methods of administration which have the effect of subjecting individuals to discrimination because of their race, color, or national origin….". The state of Alabama amended a provision in its Constitution to make English "the official language of the state of Alabama". Under the auspices of this amendment, and in the name of public safety, the Department required all state driver's license tests be administered in English. The Respondent, Sandoval (the "Respondent"), a class representative, brought a class action suit to enjoin the English only driver's tests, arguing that they violated the DOJ regulation, because they discriminated against non-English speakers due to their national origin. The District Court enjoined the license test policy. The Court of Appeals affirmed the District Court. Both the District Court and Court of Appeals rejected the argument that Title VI did not create a private cause of action.


Can individuals bring a private cause of action to enforce disparate-impact   regulations promulgated under Title VI of the Civil Rights Act of 1964?

No.

Content Type: Brief


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