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City of Los Angeles v. Lyons

Law Dictionary
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Constitutional Law Keyed to Cohen

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Bloomberg Law

Citation. 22 Ill.461 U.S. 95, 103 S. Ct. 1660, 75 L. Ed. 2d 675 (1983)

Brief Fact Summary. Adolph Lyons (Lyons) was pulled over by a Los Angeles police officer for a traffic violation. He offered no resistance, and without provocation, the police officer seized Lyons and placed him in a chokehold, rendering Lyons unconscious.

Synopsis of Rule of Law. A plaintiff who wants to invoke the jurisdiction of the Supreme Court must allege an “actual case or controversy.”ť Further, the injury complained of by plaintiff must be immediate. Past exposure to illegal conduct does not, by itself, show a present case or controversy.


Facts. In 1976, Lyons was pulled over by a Los Angeles police officer for a traffic violation. Although Lyons offered no resistance, the officer asked him to step out of the car, and proceeded to place Lyons in a chokehold, rendering Lyons unconscious. Lyons sued the municipality and sought damages and injunctive relief in District Court for the Central District of California. He asked the court to issue an injunction preventing the police department from using chokeholds in the future unless circumstances were to result in death or serious bodily injury if force was withheld. The District Court entered such an injunction. The Court of Appeals for the Ninth Circuit affirmed. The municipality appealed to the Supreme Court.

Issue. Does this case present an “actual case or controversy”ť that can be determined by the Supreme Court?
If so, does Lyons have standing to seek injunctive relief against the municipality of Los Angeles?
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