## Facts

- Kenneth Adams and other students attending educational institutions in multiple states, along with civil-rights organizations, sued the U.S. Secretary of Education and other federal officials responsible for the Department of Education’s Office for Civil Rights (OCR).
- Plaintiffs alleged that OCR failed to carry out federal civil-rights enforcement in education and continued providing federal funds to schools and state systems that were allegedly operating in violation of statutes including Title VI of the Civil Rights Act of 1964.
- The litigation began years earlier (initially styled against prior federal officials) and included district-court rulings recognizing that federal education officials had an affirmative duty to initiate enforcement action to secure compliance with Title VI rather than continue funding noncompliant programs.
- After further disputes over delays in enforcement activity, the parties negotiated a consent order (commonly described as a 1977 consent decree) that imposed time limits and procedures governing OCR’s processing of discrimination complaints and performance of compliance reviews.
- The consent order was later supplemented and modified by additional court orders addressing how OCR would proceed in particular contexts, including state higher-education desegregation matters and related enforcement activity.
- In 1982, defendants moved to vacate the consent order, arguing that changes in law and fact made ongoing decree enforcement improper. The district court denied vacatur and also issued additional relief directing steps related to state plans and enforcement progress.
- Defendants appealed. The D.C. Circuit remanded without reaching the merits, instructing the district court to make a current determination whether Article III requirements—standing and related justiciability limits—were satisfied given the case’s age and the nature of the court’s continuing role.
- On remand, defendants filed a motion to dismiss, arguing plaintiffs lacked Article III standing and that the dispute was moot or otherwise outside Article III limits.

## Issues

1. Whether the student and organizational plaintiffs had current Article III standing—injury in fact, traceability, and redressability—to pursue prospective relief concerning OCR’s alleged failures and delays in enforcing federal civil-rights requirements in education.
2. Whether the case was moot (or otherwise no longer a live case or controversy) given the passage of time and intervening changes in agency practice, law, or circumstances.
3. Whether continued enforcement of consent-decree deadlines and procedures for OCR enforcement activity exceeded Article III limits or raised separation-of-powers concerns sufficient to require dismissal.

## Decision

- The court denied defendants’ motion to dismiss.
- The court held that plaintiffs continued to satisfy Article III standing requirements for the relief at issue.
- The court determined the controversy remained live and was not moot on the record before it.
- The court concluded that Article III did not require termination of the decree-based enforcement structure merely because the litigation was long-running or because the relief included schedules and procedural requirements tied to OCR enforcement work.

## Legal Principles

- Article III standing requires (1) a concrete and particularized injury that is actual or imminent, (2) a causal link between the injury and the challenged government conduct, and (3) a likelihood that the requested relief will redress the injury.
- In suits seeking prospective relief against federal officials, standing depends on a present or threatened harm, not only on past wrongs; plaintiffs must show a real dispute continuing at the time of decision.
- Organizational plaintiffs may establish standing where the challenged conduct affects their members (associational standing) or where the organization itself suffers a legally cognizable harm connected to the conduct challenged.
- A case is not moot if the alleged unlawful conduct and its effects remain ongoing, or if effective relief remains available through judicial orders directed at defendants’ compliance with legal duties.
- Courts may enforce and supervise consent decrees and related injunctions directed at compliance with federal law when Article III requirements remain satisfied; separation-of-powers concerns may guide the scope and form of equitable relief but do not by themselves eliminate jurisdiction where a live controversy and redressable injury remain.

## Conclusion

In *Adams v. Bennett*, the district court, acting on remand, rejected the government’s Article III challenge and held that the student and organizational plaintiffs still alleged ongoing, concrete harms connected to OCR’s asserted failures and delays in enforcing federal civil-rights requirements in education, and that court enforcement of the consent-decree framework could provide meaningful relief; the court therefore denied the motion to dismiss and allowed the case to continue.


Adams v. Bennett, 675 F. Supp. 668 (1987)