Mills v. Green
159 U.S. 651, 16 S.Ct. 132, 40 L.Ed. 293 (1895)
Premium Feature
Subscribe to Lexplug to listen to the Case Podcast.
Rule of Law:
Federal courts will not decide a case if, due to an intervening event that occurs while the case is on appeal, the court can no longer grant any effective relief to the prevailing party. Such a case is considered moot and must be dismissed.
Facts:
- In 1894, South Carolina enacted a statute calling for a constitutional convention, with an election for delegates scheduled for the third Tuesday of August 1895.
- Lawrence P. Mills, a citizen of South Carolina, alleged that the state's voter registration laws were unconstitutional and overly burdensome.
- Despite repeated efforts, Mills was unable to register to vote under these laws.
- W. Briggs Green, the county supervisor of registration, was tasked with providing official registration books for the delegate election.
- Mills believed he would be denied the right to vote in the August 1895 election because his name was not on the registration books managed by Green.
Procedural Posture:
- Lawrence P. Mills filed a bill in equity in the U.S. Circuit Court for the District of South Carolina (a trial court), seeking an injunction against W. Briggs Green.
- The Circuit Court granted a temporary injunction, which was later continued after a hearing.
- Green, the defendant, appealed the injunction to the U.S. Circuit Court of Appeals (an intermediate appellate court).
- The Circuit Court of Appeals reversed the lower court's order, dissolved the injunction, and directed that Mills's bill be dismissed.
- Mills, the plaintiff and now appellant, appealed the dismissal to the Supreme Court of the United States.
Premium Content
Subscribe to Lexplug to view the complete brief
You're viewing a preview with Rule of Law, Facts, and Procedural Posture
Issue:
Does a federal appellate court have jurisdiction to decide a case where the event that the plaintiff sought to participate in has already occurred, rendering any potential relief from the court ineffectual?
Opinions:
Majority - Mr. Justice Gray
No. When an event occurs that makes it impossible for the court to grant any effectual relief, the controversy becomes moot, and the court will not proceed to a formal judgment. The duty of the court is to decide actual controversies, not to give opinions on abstract propositions. The entire purpose of Mills's lawsuit was to secure his right to vote in the election for delegates on the third Tuesday of August 1895. By the time the appeal was heard by the Supreme Court, that date had passed, the election had occurred, and the constitutional convention had assembled. The Court takes judicial notice of these public events. Because the Court cannot turn back time to grant Mills the relief he originally sought—the ability to vote in that specific election—the case is moot and must be dismissed.
Analysis:
This case is a foundational articulation of the mootness doctrine, a key component of the 'case or controversy' requirement under Article III of the Constitution. It establishes that federal courts are not forums for providing advisory opinions or resolving disputes that no longer have a practical effect on the parties' rights. The decision solidifies the principle that if events subsequent to the filing of a case resolve the dispute or make a judicial decision irrelevant, the court must dismiss the case. This principle conserves judicial resources and remains a crucial threshold for federal court jurisdiction.
Unlock the full brief for Mills v. Green