University of Texas et al. v. Camenisch
451 U.S. 390 (1981)
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Rule of Law:
When an appeal is taken from a grant of a preliminary injunction and the underlying act sought to be enjoined has been completed, the appeal of the preliminary injunction is moot. An appellate court cannot then proceed to decide the merits of the underlying case, which must be remanded to the trial court for a full hearing.
Facts:
- Walter Camenisch was a deaf graduate student at the University of Texas.
- The University of Texas receives federal financial assistance.
- Camenisch requested that the University pay for a sign-language interpreter to enable him to participate in his studies.
- The University refused to pay for the interpreter, stating that Camenisch did not meet its established financial need criteria for student assistance.
- The University was willing to allow Camenisch to have an interpreter present at his own expense.
- During the course of the litigation, the University paid for the interpreter service under court order, and Camenisch completed his studies and graduated.
Procedural Posture:
- Walter Camenisch filed a complaint against the University of Texas in the U.S. District Court for the Western District of Texas, seeking preliminary and permanent injunctive relief.
- The District Court granted a preliminary injunction requiring the University to pay for an interpreter, conditioned on Camenisch posting a $3,000 security bond.
- The University of Texas, as defendant, appealed the grant of the preliminary injunction to the U.S. Court of Appeals for the Fifth Circuit.
- The Court of Appeals affirmed the District Court's grant of the preliminary injunction.
- The Supreme Court of the United States granted certiorari to review the decision of the Court of Appeals.
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Issue:
Does the fact that a preliminary injunction has been fully carried out, rendering the question of its issuance moot, permit an appellate court to decide the underlying merits of the case rather than remanding for a full trial?
Opinions:
Majority - Justice Stewart
No. When the issue of a preliminary injunction's validity becomes moot, an appellate court cannot decide the ultimate merits of the dispute. The purpose of a preliminary injunction is solely to preserve the parties' positions until a trial on the merits, and it is granted based on procedures less formal and evidence less complete than a full trial. A finding of a "likelihood of success" for a preliminary injunction is not equivalent to a final determination of success on the merits. Because the findings of fact and conclusions of law from a preliminary injunction hearing are not binding at trial, the case must be remanded to the district court for a full trial to resolve the remaining issue of who should ultimately bear the cost of the interpreter.
Concurring - Chief Justice Burger
Yes, I agree that the case must be remanded for a trial on the merits. It is important to emphasize that this opinion does not intimate that the respondent has any likelihood of success on the merits. The trial court must determine whether the federal regulations compelling the University to pay for an interpreter exceed the authority granted by Congress under § 504 of the Rehabilitation Act. The University's refusal was based solely on neutral financial need criteria, not on discrimination, a key issue that must be resolved at trial.
Analysis:
This case establishes a critical procedural rule distinguishing between preliminary and permanent injunctions in the context of mootness. It clarifies that an appellate court's jurisdiction is limited to the order being appealed. When a preliminary injunction becomes moot, the court cannot use that as an opportunity to shortcut the trial process and rule on the ultimate merits of the case. This decision protects the procedural right of litigants to a full trial on the merits, with complete evidence and formal procedures, before a final, binding judgment is rendered. It prevents appellate courts from overstepping their role by deciding issues not fully litigated in the trial court.
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