Arizonans for Official English v. Arizona
520 U.S. 43 (1997)
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Rule of Law:
When a plaintiff's claim for prospective relief becomes moot due to a voluntary change in circumstances, the case cannot be kept alive by a late-stage request for nominal damages if there is no proper party against whom such damages can be awarded. Federal courts should also utilize state certification procedures to obtain an authoritative interpretation of a novel state law before ruling on its constitutionality.
Facts:
- In 1988, Arizona voters passed Article XXVIII of the Arizona Constitution, making English the state's official language and requiring its use in all government functions and actions.
- Maria-Kelly F. Yniguez, a bilingual insurance claims manager for the State of Arizona, regularly used both Spanish and English to communicate with the public as part of her job duties.
- Yniguez feared that Article XXVIII would prohibit her from speaking Spanish at work and subject her to disciplinary action or termination.
- The Arizona Attorney General issued a formal opinion interpreting Article XXVIII narrowly, stating it applied to 'official acts' of government but permitted employees to use other languages to facilitate the delivery of services.
- No supervisor ever told Yniguez to stop using Spanish in the performance of her duties after the passage of Article XXVIII.
- In April 1990, while the case was pending, Yniguez voluntarily resigned from her state position to take a job in the private sector, where Article XXVIII did not apply to her.
Procedural Posture:
- Maria-Kelly F. Yniguez sued the State of Arizona and several state officials in the U.S. District Court for the District of Arizona, challenging the constitutionality of Article XXVIII.
- The District Court dismissed the State of Arizona as a defendant on Eleventh Amendment grounds but allowed the suit to proceed against Governor Mofford in her official capacity.
- The District Court declared Article XXVIII unconstitutional but denied Yniguez's request for an injunction.
- Governor Mofford announced she would not appeal the judgment.
- Arizonans for Official English (AOE) and its chairman, Robert Park, sought to intervene to appeal the decision, but the District Court denied their motion.
- AOE and Park appealed the denial of intervention to the U.S. Court of Appeals for the Ninth Circuit.
- The Ninth Circuit reversed the District Court, holding that AOE and Park had standing to intervene and appeal the merits of the case.
- After the State's Attorney General informed the court that Yniguez had left her state job, the Ninth Circuit held that her claim for prospective relief was moot but allowed the case to continue based on a claim for nominal damages.
- A Ninth Circuit panel, and subsequently a divided en banc court, affirmed the District Court's judgment, finding Article XXVIII unconstitutional and ordering an award of nominal damages against the State.
- AOE and Park petitioned the U.S. Supreme Court for a writ of certiorari, which was granted.
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Issue:
Does a live case or controversy remain for a federal appellate court to adjudicate when the plaintiff-employee challenging a state law voluntarily leaves her government job, thereby mooting her claim for injunctive relief, and subsequently asserts a claim for nominal damages?
Opinions:
Majority - Justice Ginsburg
No, a live case or controversy does not remain. The case became moot when the plaintiff's personal stake in the outcome ceased to exist, and this jurisdictional defect could not be cured by a belated claim for nominal damages. An actual controversy must exist at all stages of federal court review. Yniguez's claim for prospective relief, such as an injunction, became moot the moment she voluntarily left her state employment in 1990, as she was no longer subject to Article XXVIII. The Ninth Circuit's attempt to save the case by allowing a claim for nominal damages failed because the claim was improperly asserted against the State of Arizona. Under 42 U.S.C. § 1983, a state is not a 'person' who can be sued for damages, and the Ninth Circuit had previously ruled the State was not a party to the appeal. This manufactured claim against a non-party could not revive an otherwise dead case. The Court also heavily criticized the lower courts for failing to certify the novel question of Article XXVIII's meaning to the Arizona Supreme Court, which could have avoided or simplified the federal constitutional question and showed proper respect for judicial federalism.
Analysis:
This decision strongly reaffirms the constitutional doctrine of mootness and the prohibition against advisory opinions, demonstrating that federal courts will not entertain cases where the plaintiff's concrete personal stake has disappeared. It significantly curbs the ability of litigants to use last-minute claims for nominal damages as a tool to keep an otherwise moot case alive for the sole purpose of obtaining a precedential ruling. Furthermore, the opinion serves as a powerful directive to lower federal courts to respect principles of federalism by using state certification procedures for unsettled state law questions, promoting judicial restraint and avoiding unnecessary constitutional adjudication.
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