Summary
The Supreme Court held that private individuals may not bring a freestanding private action to enforce disparate-impact regulations promulgated under § 602 of Title VI of the Civil Rights Act of 1964. The Court distinguished the private right of action available to enforce § 601, which reaches intentional discrimination, from enforcement of regulations that prohibit conduct with a disparate impact. The judgment of the Eleventh Circuit was reversed.
Topics
Practice areas
Questions Presented
- Whether private individuals may sue directly to enforce disparate-impact regulations promulgated under § 602 of Title VI.
- Whether the private right of action to enforce § 601 of Title VI extends to conduct prohibited by disparate-impact regulations that goes beyond § 601's prohibition of intentional discrimination.
Holdings
- Private individuals may sue to enforce § 601 of Title VI and obtain injunctive relief and damages.
- Title VI does not create a freestanding private right of action to enforce disparate-impact regulations promulgated under § 602 when the challenged conduct is not also prohibited by § 601.
Key quotations
“Like substantive federal law itself, private rights of action to enforce federal law must be created by Congress.” (286-287)
“Language in a regulation may invoke a private right of action that Congress through statutory text created, but it may not create a right that Congress has not.” (291)
“Neither as originally enacted nor as later amended does Title VI display an intent to create a freestanding private right of action to enforce regulations promulgated under § 602.” (293)
Factual background
The Alabama Department of Public Safety accepted federal financial assistance from the Departments of Justice and Transportation and was therefore subject to Title VI restrictions. After Alabama amended its Constitution to designate English as the official state language, the Department administered driver's-license examinations only in English. Sandoval, representing a class of non-English speakers, alleged that the policy had a disparate impact based on national origin and sought injunctive relief under a Title VI regulation.
Procedural history
Sandoval brought a class action in the United States District Court for the Middle District of Alabama, arguing that Alabama's English-only driver's-license examination policy violated a Department of Justice disparate-impact regulation issued under Title VI. The district court enjoined the policy and ordered accommodations for non-English speakers. The Eleventh Circuit affirmed, rejecting the argument that Title VI provided no private cause of action to enforce the regulation. The Supreme Court reversed.