## Facts

- Adolph Lyons alleged that Los Angeles police officers stopped him for a traffic violation around 2:00 a.m. and, without provocation or resistance, applied a chokehold that rendered him unconscious and injured his larynx.
- Lyons sued the City of Los Angeles and individual officers seeking (1) damages for the past incident and (2) declaratory and injunctive relief to bar chokeholds except where a suspect reasonably appeared to pose an immediate deadly-force threat.
- The complaint alleged that the City authorized, instructed, and encouraged routine chokehold use in many non-deadly situations, resulting in numerous injuries, and that Lyons feared future police contact could lead to a repeat incident.
- The district court issued a preliminary injunction restricting chokehold use to deadly-force situations; the Ninth Circuit affirmed.
- The Supreme Court granted review limited to whether Lyons had standing to seek prospective injunctive (and related declaratory) relief; policy changes announced during litigation did not moot the request for prospective relief.

## Issues

1. Whether Lyons’s request for prospective relief presented an Article III “case or controversy.”
2. Whether Lyons had standing to seek an injunction and declaratory judgment against future LAPD chokehold use absent a real and immediate threat that he personally would be subjected to the practice again.

## Decision

- The Supreme Court reversed in relevant part, holding that Lyons lacked standing to pursue injunctive and declaratory relief.
- Past exposure to allegedly unlawful conduct did not, by itself, establish a present controversy for prospective relief without continuing adverse effects or an imminent threat of recurrence.
- Lyons’s asserted risk of being choked again depended on multiple contingencies and was too speculative to qualify as a “real and immediate” threat.
- The Court emphasized that standing must be established for each form of relief requested: Lyons could pursue damages for the past incident but could not obtain prospective equitable relief.
- Because Article III standing was absent for the prospective claims, the federal courts lacked jurisdiction to maintain the injunction.

## Legal Principles

- Article III requires a plaintiff seeking equitable relief to show a personal, concrete injury or imminent threat of injury that is “real and immediate,” not conjectural or hypothetical.
- Past injury supports standing for damages but does not automatically establish standing for injunctive or declaratory relief directed at future conduct.
- A plaintiff must demonstrate standing separately for each type of relief sought; the remedy sought must be tied to a likelihood of future personal harm.
- Federal courts will not issue broad injunctions restructuring state or local law-enforcement practices without a showing of imminent, personal harm, given limits on equitable jurisdiction and concerns about ongoing judicial supervision of local officials.

## Conclusion

The Court held that Lyons could not obtain injunctive or declaratory relief against LAPD chokeholds because he failed to show a sufficiently likely, personal risk of being subjected to a chokehold again, even though his damages claims based on the past incident were not barred.


City of Los Angeles v. Lyons, 461 U.S. 95 (1983)