## Facts

- Arizona voters adopted a state constitutional amendment declaring English the State’s official language and requiring government to act in English, with limited exceptions and private enforcement authorization.
- A state employee who used English and Spanish at work sued state officials under 42 U.S.C. § 1983, seeking declaratory and injunctive relief against the amendment’s enforcement, alleging it broadly barred non-English speech in official duties.
- The district court dismissed several defendants, treated the Governor as the remaining proper defendant, construed the amendment broadly, and held it unconstitutional; it declined to obtain an authoritative state-court construction.
- The employee later left state employment for a private-sector job and did not allege an intent to return.
- The Ninth Circuit nevertheless reached the merits and upheld invalidation of the amendment, reasoning that a nominal-damages request could be inferred from the complaint’s general prayer for relief.
- The initiative’s sponsoring organization sought to defend the measure after state officials declined further appeal.

## Issues

1. Whether the plaintiff’s departure from state employment mooted her claims for prospective relief under Article III.
2. Whether a court may preserve jurisdiction by inferring an unpleaded claim for nominal damages from a general request for “other relief.”
3. Whether initiative sponsors have Article III standing to appeal and defend a state constitutional amendment when state officials decline to do so.
4. Whether federal courts should refrain from definitive constructions of novel state constitutional provisions without state-court guidance.

## Decision

- The Supreme Court vacated the Ninth Circuit’s judgment and remanded with directions to dismiss the action as moot.
- The plaintiff’s claim for prospective relief became moot once she left state employment and disclaimed any intention to return.
- The Ninth Circuit improperly “read into” the complaint a nominal-damages claim to avoid mootness.
- The initiative sponsors lacked the direct, personal stake required for Article III standing to maintain the appeal.
- The Court expressed no view on the amendment’s proper interpretation or constitutionality.

## Legal Principles

- Article III standing and a live case or controversy must exist at each stage of federal litigation, not merely at filing.
- Claims for declaratory and injunctive relief based on employment conditions generally become moot when the plaintiff leaves the job and shows no realistic prospect of returning.
- Federal courts may not manufacture jurisdiction by inferring a nominal-damages claim not fairly pleaded or pursued in the litigation.
- A generalized interest in defending or seeing enforcement of a voter-enacted measure does not, without more, establish Article III standing for private initiative sponsors.
- When the meaning of a state constitutional provision is unsettled and material to the federal question, federal courts should avoid issuing definitive constructions without state-court input.

## Conclusion

The Court ended the case on justiciability grounds, holding that the plaintiff’s post-filing change in employment mooted her request for prospective relief and that neither an implied nominal-damages theory nor initiative-sponsor participation supplied the Article III controversy needed to sustain federal jurisdiction.


Arizonans for Official English v. Arizona, 520 U.S. 43 (1997)