DeFunis v. Odegaard – Case Brief Summary

Summary of DeFunis v. Odegaard, 416 U.S. 312, 94 S. Ct. 1704, 40 L. Ed. 2d 164 (1974).

Facts

Petitioner DeFunis, a white applicant to the University of Washington law school, sued the Board of Regents of the University of Washington in state court after he was denied admission. DeFunis alleged that the law school discriminated against applicants of certain races and ethnicities, including whites, by admitting minority applicants with significantly lower undergraduate grades and LSAT scores. DeFunis maintained that his rejection was predicated on racial discrimination in violation of the Equal Protection Clause of the Fourteenth Amendment.

The District Court granted DeFunis injunctive relief and ordered the law school to admit him. When DeFunis was in his second year of law school, the Supreme Court of Washington reversed, holding that the admissions policy was not unconstitutional. The Supreme Court of the United States granted DeFunis’ petition for a writ of certiorari and stayed the judgment of the Supreme Court of Washington pending final disposition of the case.

The case came before the Supreme Court of the United States for a full hearing when DeFunis was in his final year of law school. Although the law school assured that it would allow DeFunis to graduate regardless of the Court’s decision, both parties contended that mootness did not exist to block formal adjudication of the matter.

Issue

  • Can a case be adjudicated when subject matter jurisdiction is lacking due to mootness, if adjudication of the suit would resolve an important social issue?

Holding and Rule

  • No. When a federal court’s determination of a legal issue is no longer necessary to compel the result originally sought, the case is moot and federal courts lack the power to hear it.

The constitutional basis of the mootness doctrine is found in Article III of the Constitution which requires the existence of a case or controversy. Thus, a real and live controversy must exist at every stage of review.

The court held that when the original controversy has disappeared prior to development of the suit, it is deemed moot and a trial must not proceed for lack of subject matter jurisdiction. That a matter deemed moot leaves an important social issue unresolved is of no consequence.

Dissent (Douglas)

Due to the social significance of the issue involved in this case, this matter should be adjudicated despite its apparent mootness.

Dissent (Brennan)

Because of the social significance of the issue involved in this case, failure to adjudicate this matter now will only result in a future duplication of the court effort.

See Brown v. Board of Education for a constitutional law case brief involving an issue of race based discrimination in which the Supreme Court held that segregation is unconstitutional for violating the Equal Protection Clause of the Fourteenth Amendment.


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