Iron Arrow Honor Society v. Heckler
78 L. Ed. 2d 58, 464 U.S. 67, 1983 U.S. LEXIS 119 (1983)
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Rule of Law:
A case becomes moot, and a federal court loses jurisdiction, when an intervening event, such as the independent and unequivocal action of a third party, makes it impossible for the court to grant any effective relief to the prevailing party.
Facts:
- Iron Arrow Honor Society is an all-male honorary organization at the University of Miami.
- The Society traditionally conducts its public 'tapping' initiation ceremony on University property.
- The University of Miami receives federal funds, making it subject to Title IX, which prohibits sex discrimination in federally funded education programs.
- On July 15, 1980, the University's Trustee Executive Committee adopted a policy requiring all student organizations to follow a code of nondiscrimination.
- On September 23, 1982, the University's president sent a letter to Iron Arrow stating the University's unequivocal position that the society could not conduct its activities on campus until it discontinued its discriminatory membership policy.
- The president's letter explicitly stated that this decision was based on what the University believed was right and that the University would maintain this position regardless of the outcome of Iron Arrow's lawsuit.
Procedural Posture:
- Iron Arrow Honor Society sued the Secretary of Health, Education, and Welfare in the U.S. District Court for the Southern District of Florida.
- The District Court initially dismissed the suit for lack of standing.
- On appeal, the U.S. Court of Appeals for the Fifth Circuit reversed the standing determination and remanded.
- On remand, the District Court granted summary judgment in favor of the Secretary.
- The U.S. Court of Appeals for the Fifth Circuit affirmed the District Court's judgment.
- The U.S. Supreme Court granted certiorari, vacated the judgment, and remanded for reconsideration in light of a recent precedent.
- On the second remand, the U.S. Court of Appeals for the Fifth Circuit again affirmed the District Court's decision.
- Iron Arrow again petitioned the U.S. Supreme Court for a writ of certiorari.
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Issue:
Does a university's unequivocal, independent decision to ban a discriminatory student organization from campus, regardless of the outcome of the organization's lawsuit against a federal official attempting to compel that ban, render the lawsuit moot?
Opinions:
Majority - Per Curiam
Yes. A university's unequivocal and independent decision to ban a discriminatory organization from campus renders the organization's lawsuit against a federal official moot. To satisfy the Article III case-or-controversy requirement, a litigant must have an actual injury that can be redressed by a favorable judicial decision. In this case, Iron Arrow's injury is being excluded from campus. However, it is now the action of the University, not the Secretary, that excludes Iron Arrow. The University has stated unequivocally that it will maintain this ban regardless of this lawsuit's outcome. Therefore, even if Iron Arrow were to prevail against the Secretary, the court could not grant any effective relief because the University would still enforce its ban. The 'voluntary cessation' doctrine, which makes it difficult for a defendant to moot a case by stopping the challenged conduct, is not directly applicable because the action was taken by a third-party nondefendant, the University. Even so, the University's public and definitive statement makes it clear there is 'no reasonable likelihood' it will reverse its decision, thus resolving the controversy between Iron Arrow and the University.
Dissenting - Justice Brennan
No. The issue of mootness is not yet resolved. The case should be remanded because mootness depends on uncertain factual issues concerning the University's present intentions and future conduct. The Supreme Court should not decide this factual question; rather, a lower court should hold a hearing to determine if the University's decision is truly final and independent.
Dissenting - Justice Stevens
No. The university's decision does not render the case moot because the decision was not truly voluntary. A case is moot only when the issues are no longer 'live' or the parties lack a legally cognizable interest in the outcome. Here, the legal issue of the Secretary's authority is still live. The University's decision to ban Iron Arrow came only after years of coercive pressure and the ongoing threat of losing federal funds. This threat prevents the University from re-examining its decision free from coercion. Iron Arrow retains a legally cognizable interest in having that coercive threat removed, which would allow the University to make a truly free and independent choice about its relationship with the society. Therefore, the case is not moot.
Analysis:
This case provides a key clarification of the mootness doctrine under Article III, particularly regarding the actions of third parties. The Court established that an independent, intervening decision by a non-party can render a case moot if it makes a judicial remedy ineffective. It distinguishes this situation from the standard 'voluntary cessation' doctrine, where a defendant's cessation of challenged conduct is viewed with skepticism. This ruling emphasizes the practical requirement of redressability for a case to remain a live controversy, impacting future cases where the actions of entities not directly involved in the litigation fundamentally alter the dispute and the possibility of relief.
