No. To get a court to issue a preventative order (called an injunction), you must show a real and immediate threat that you will be harmed again. Lyons couldn't prove he was any more likely than any other driver in L.A. to be pulled over and choked in the future. His fear was just a possibility, not a certainty. While he can sue the city for money for what happened in the past, he doesn't have the right ('standing') to ask a federal court to stop the policy for the future.

Yes. This is the wrong way to look at it. Lyons is already in court suing the city for money because of its dangerous chokehold policy. That means there's a real, active legal dispute about whether the policy is constitutional. Since the court is already handling the case, it should have the power to order the city to stop the policy if it's found to be illegal. The majority's rule lets the police keep a deadly policy as long as they are willing to pay for the damages, which means courts are powerless to prevent future harm.

The Supreme Court said Lyons didn't have a strong enough case to ask the court to limit police chokeholds in the future. They said federal courts can only get involved if someone shows a real and immediate threat of being harmed again. Just because something bad happened to Lyons in the past doesn't mean the courts can step in now if there's no proof it will happen to him again.

The dissenting judges disagreed, arguing that Lyons had shown a good chance he could be choked again, especially since it happened before due to the city's chokehold policy. They said the majority was making it too hard for people to get courts to prevent future harm by requiring extra proof for each specific thing they wanted the court to do.

No, Lyons cannot ask us to limit police chokeholds in the future because he does not have a strong enough case. We can only get involved if someone shows a real and immediate threat of being harmed again. Just because something bad happened to Lyons in the past does not mean we can step in now if there is no proof it will happen to him again.

Yes, Lyons can ask us to stop the police from using chokeholds in the future because he has shown a good chance he could be choked again, especially since it happened before due to the city's chokehold policy. The majority makes it too hard for people to prevent future harm by requiring extra proof for each specific remedy sought.

Importantly, there must be "a showing of any real or immediate threat that the plaintiff will be wronged again—a likelihood of substantial and immediate irreparable injury."

The threat of future injury to the plaintiff "must be both real and immediate, not conjectural or hypothetical."

Federal courts are courts of limited jurisdiction and in considering a request for preliminary injunctive relief, the Court is bound by the requirement that as a preliminary matter, it have before it an actual case or controversy.

The Court finds that plaintiff's claim of future injury is too speculative to support standing to seek injunctive relief.

"The plaintiff must show that he `has sustained or is immediately in danger of sustaining some direct injury'as the result of the challenged official conduct and the injury or threat of injury must be both `real and immediate'not `conjectural'or `hypothetical.'"

Past exposure to illegal conduct does not in itself show a present case or controversy regarding injunctive relief... if unaccompanied by any continuing, present adverse effects

T] he capable-of-repetition doctrine applies only in exceptional situations, and generally only where the named plaintiff can make a reasonable showing that he will again be subjected to the alleged illegality

"Because injunctions regulate future conduct, a party has standing to seek injunctive relief only if the party alleges, and ultimately proves, a real and immediate—as opposed to a merely conjectural or hypothetical—threat of future injury."

—plaintiffs must show that further injury is imminent, or that they are likely to suffer the alleged injuries again in the future, to obtain injunctive relief.

The plaintiff in Lyons sought to enjoin Los Angeles police officers from using a chokehold that officers had used against him during a traffic stop.

No. A plaintiff seeking an injunction must demonstrate a real and immediate threat of future injury, and past harm alone does not confer standing for prospective relief. To satisfy Article III's 'case or controversy' requirement, the threat of injury must be 'real and immediate,' not 'conjectural' or 'hypothetical.' Lyons's assertion that he might again be stopped and choked by police is purely speculative; it depends on a chain of unlikely future events. His standing for a damages claim does not translate into standing for an injunction. Under the Court's precedents in O'Shea v. Littleton and Rizzo v. Goode, the conjectural nature of a future encounter with law enforcement is insufficient to establish the live controversy required for equitable relief. Furthermore, principles of comity and federalism counsel restraint in federal courts issuing injunctions against state law enforcement authorities.

Yes. A plaintiff who has a live claim for damages based on an unconstitutional municipal policy has standing to seek all appropriate relief, including an injunction against that same policy. The majority improperly fragments the standing inquiry by requiring a separate showing for each form of relief sought. Lyons's damages claim against the City requires him to prove the existence of an unconstitutional chokehold policy, which creates a 'case or controversy' over that policy's legality. Once the court's jurisdiction is properly invoked to adjudicate that controversy, it has the power to grant any suitable remedy. The majority’s holding immunizes unconstitutional policies from prospective challenges, allowing the government to continue a harmful practice as long as it is willing to pay damages to its victims.

The Supreme Court held that Lyons did not have standing to seek injunctive relief because he failed to demonstrate a real and immediate threat of future injury. The Court emphasized that federal courts are courts of limited jurisdiction and that the plaintiff's claim of future injury was too speculative to support standing for injunctive relief. The Court also noted that past exposure to illegal conduct does not establish a present case or controversy if unaccompanied by continuing, present adverse effects, and that the capable-of-repetition doctrine applies only in exceptional situations where the plaintiff can reasonably show that they will again be subjected to the alleged illegality.

The dissent argued that Lyons had standing to seek injunctive relief because he alleged a sufficient likelihood that he would again be subjected to the unlawful chokehold. The dissent contended that Lyons' risk of future injury should be assessed in light of his past injury and the finding that the chokehold was applied pursuant to an official policy. The dissent also criticized the majority for fragmenting the standing inquiry and imposing a separate standing hurdle for each form of relief sought, arguing that this departs from established standing principles and the traditional conception of the remedial powers of federal courts.

We hold that Lyons did not have standing to seek injunctive relief because he failed to demonstrate a real and immediate threat of future injury. We emphasize that federal courts are courts of limited jurisdiction and that the plaintiff's claim of future injury was too speculative to support standing for injunctive relief. We also note that past exposure to illegal conduct does not establish a present case or controversy if unaccompanied by continuing, present adverse effects, and that the capable-of-repetition doctrine applies only in exceptional situations where the plaintiff can reasonably show that he will again be subjected to the alleged illegality.

I respectfully dissent. Lyons has standing to seek injunctive relief because he alleged a sufficient likelihood that he would again be subjected to the unlawful chokehold. Lyons’ risk of future injury should be assessed in light of his past injury and the finding that the chokehold was applied pursuant to an official policy. I also criticize the majority for fragmenting the standing inquiry and imposing a separate standing hurdle for each form of relief sought. This approach departs from established standing principles and the traditional conception of the remedial powers of federal courts.

City of Los Angeles v. Lyons

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