City of Los Angeles v Lyons
S. Ct. 1983
Author: Sam Biers

Facts: Adolph Lyons was stopped by LA police for a traffic violation, and without any resistance, he was subdued by a choke hold.  The application caused damage to Mr. Lyons larynx.  He subsequently filed an action.  Count V requested injunctive relief against the City barring use of the control holds.

Issue: Whether Lyons satisfied the prerequisites for seeking injunctive relief in the Federal Court?

Holding: No

Procedure: District Court granted judgment for City.  Ct of App reversed.  Reversed by S. Ct.

Rule: Ripeness arises when an actual case has ripened or matured into a controversy worthy of adjudication.

Ct. Rationale: Past exposure to illegal conduct does not in itself show a present case or controversy.  Lyons’ request depended upon whether he was likely to suffer future injury from the use of chokeholds by LA police officers for traffic stops.  Lyons would have to assert either the all police perform this way or that the City orders them to perform.

Lyons’ case is not ripe because of the speculative nature of his claim. Predictions of future behavior are beyond the court’s functions.

DISSENT: Whether Lyons can show that the City’s chokehold policy is unconstitutional?

Lyons’ claim for damages gives him standing to sue, success therein depends on his proving whether the conduct was unconstitutional.  Standing under Article III is established by an allegation of threatened or actual injury. Lyons suffered an actual past injury, as the findings of the District Ct show.

Pl A: Lyons should argue the actual injury and damages sufficient to determine Case and Controversy.

Def A: The City should argue the policy is not aimed at all traffic stops, only those where the officer’s safety is in question.