Facts
- Marco DeFunis, Jr. applied for admission to the University of Washington School of Law, a state institution, and was denied.
- He alleged the law school admissions process gave preferential treatment to minority applicants, resulting in the rejection of better-qualified nonminority applicants.
- DeFunis sued university officials for injunctive relief, claiming the admissions policy violated the Fourteenth Amendment’s Equal Protection Clause.
- A Washington trial court found the admissions procedures unconstitutional and ordered DeFunis admitted; he enrolled.
- The Washington Supreme Court reversed, upholding the admissions policy.
- A stay permitted DeFunis to remain enrolled while Supreme Court review was pending.
- By the time the case was argued, DeFunis was in his final year; the law school represented he could complete his final term and graduate regardless of the outcome.
Issues
- Whether, under Article III, a live case or controversy existed when the petitioner would graduate regardless of the Court’s decision.
- Whether the dispute fell within exceptions to mootness, including voluntary cessation or “capable of repetition, yet evading review.”
Decision
- The Supreme Court dismissed the case as moot in a per curiam decision.
- The Court vacated the Washington Supreme Court’s judgment and remanded with instructions to dismiss.
- The Court declined to decide the constitutional merits of the admissions policy.
- The Court rejected application of mootness exceptions, including voluntary cessation and “capable of repetition, yet evading review.”
- Justices Douglas and Brennan (joined by Douglas, White, and Marshall) dissented, arguing the case should be decided on the merits.
Legal Principles
- Article III limits federal courts to deciding live disputes that can affect the parties’ rights; this requirement must persist through all stages of review.
- A case is moot when the court can no longer grant effective relief to the litigant.
- Mootness is not avoided merely because the challenged policy continues to operate; the plaintiff must retain a personal stake in the requested relief.
- The voluntary cessation exception does not apply when mootness turns on the plaintiff’s inability to benefit from relief rather than on a defendant’s discretionary stopping of the challenged conduct.
- The “capable of repetition, yet evading review” exception generally requires a reasonable expectation that the same complaining party will be subjected to the same action again; recurrence for others is insufficient.
- Public importance alone cannot supply jurisdiction where no live case or controversy exists.
Conclusion
Because the law school’s commitment ensured DeFunis would complete his final term and graduate regardless of the Court’s ruling, the Supreme Court held that no effective relief remained available and dismissed the case as moot without reaching the equal protection challenge to the admissions program.