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Alexander v. Sandoval

Alexander v. Sandoval
Seal of the United States Supreme Court.svg
Argued January 16, 2001
Decided April 24, 2001
Full case name James Alexander, Director, Alabama Department of Public Safety, et al., Petitioners v. Martha Sandoval, individually and on behalf of all others similarly situated
Citations 532 U.S. 275 (more)
121 S. Ct. 1511; 149 L. Ed. 2d 517; 2001 U.S. LEXIS 3367; 69 U.S.L.W. 4250; 80 Empl. Prac. Dec. (CCH) P40,456; 2001 Cal. Daily Op. Service 3194; 2001 Daily Journal DAR 3941; 2001 Colo. J. C.A.R. 2042; 14 Fla. L. Weekly Fed. S 206
Prior history 7 F. Supp. 2d 1234 (M.D. Ala. 1998), aff'd, 197 F.3d 484 (11th Cir. 1999), cert. granted, 530 U.S. 1305 (2000).
Subsequent history 268 F.3d 1065 (11th Cir. 2001).
Holding
There is no private right of action to enforce disparate-impact regulations promulgated under Title VI of the Civil Rights Act of 1964.
Court membership
Case opinions
Majority Scalia, joined by Rehnquist, O'Connor, Kennedy, Thomas
Dissent Stevens, joined by Souter, Ginsburg, Breyer
Laws applied
Civil Rights Act of 1964, Title VI

Alexander v. Sandoval, 532 U.S. 275 (2001), was a US Supreme Court decision that a regulation enacted under Title VI of the Civil Rights Act of 1964 did not include a private right of action to allow private lawsuits based on evidence of disparate impact.

In 1990, Alabama added an amendment to its state constitution to make English the state's official language. Thereafter, James Alexander, Director of the Alabama Department of Public Safety, ordered that the test for Alabama driver's license test to be given only in English.

Plaintiff Martha Sandoval sued Alexander and other defendants in the United States District Court for the Middle District of Alabama and claimed that the English-only test policy was discriminatory.

Sandoval sued under Title VI of the Civil Rights Act of 1964. Two sections of Title VI would prove important to her lawsuit. The first was section 601, which prohibits discrimination on the basis of "race, color, or national origin" by programs or agencies that receive federal funding, such as the Alabama Department of Public Safety. The other was section 602, which authorizes federal agencies "to effectuate the provisions of [section 601]... by issuing rules, regulations or orders of general applicability."

In her lawsuit, Sandoval invoked a regulation that the US Department of Justice had promulgated under section 602. The regulation prohibited agencies and programs receiving federal funding from taking actions that had a disparate impact on persons of a certain race, color, or nationality. She sought to enjoin Alabama's policy of giving the tests for driver's licenses in English only. She argued that the policy had a disparate impact on those born outside the United States because it denied non-English-speakers, who are disproportionately born outside the US, the opportunity to obtain driver's licenses.


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