Arizonans for Official English v. Arizona

Arizonans for Official English v. Arizona, 520 U.S. 43 (1996), was a United States Supreme Court decision that held that Article III required standing for each stage of litigation, rather than just when a complaint is filed.[1]

Arizonans for Official English v. Arizona
Argued December 4, 1996
Decided March 3, 1997
Full case nameArizonans for Official English and Robert D. Park, petitioners v. Arizona, et al.
Citations520 U.S. 43 (more)
117 S. Ct. 1055; 137 L. Ed. 2d 170
Case history
PriorYniguez v. Mofford, 730 F. Supp. 309 (D. Ariz. 1990); Yniguez v. Arizona, 939 F.2d 727 (9th Cir. 1991); cert. granted, 520 U.S. 43 (1997).
Court membership
Chief Justice
William Rehnquist
Associate Justices
John P. Stevens · Sandra Day O'Connor
Antonin Scalia · Anthony Kennedy
David Souter · Clarence Thomas
Ruth Bader Ginsburg · Stephen Breyer
Case opinion
MajorityGinsburg, joined by unanimous
Laws applied
U.S. Const. art. III

Background

In 1988, ballot initiative Proposition 106, mandating that state employees speak only English on the job passed with 50.5% of the vote.[2][3] Arizona insurance claims manager Maria-Kelly Yniguez sued to overturn this law because she was concerned that she would be fired for speaking Spanish to claimants. However, on February 6, 1990, judge Paul Rosenblatt of the United States District Court for the District of Arizona ruled that the law violated the free speech clause of the First Amendment to the United States Constitution.[4][5] The group Arizonans for Official English appealed to the United States Court of Appeals for the Ninth Circuit, and on December 7, 1994, that court upheld the Arizona federal court ruling.[6][7] The U.S. Supreme Court accepted an appeal of the Ninth Circuit ruling on March 26, 1996.[8]

Opinion of the Court

Associate Justice Ruth Bader Ginsburg wrote for a unanimous court:

Federal courts lack competence to rule definitively on the meaning of state legislation, see, e.g., Reetz v. Bozanich, 397 U.S. 82, 86-87, 25 L. Ed. 2d 68, 90 S. Ct. 788 (1970), nor may they adjudicate challenges to state measures absent a showing of actual impact on the challenger, see, e.g., Golden v. Zwickler, 394 U.S. 103, 110, 22 L. Ed. 2d 113, 89 S. Ct. 956 (1969). The Ninth Circuit, in the case at hand, lost sight of these limitations. The initiating plaintiff, Maria-Kelly F. Yniguez, sought federal-court resolution of a novel question: the compatibility with the Federal Constitution of a 1988 amendment to Arizona's Constitution declaring English "the official language of the State of Arizona"-- "the language of . . . all government functions and actions." Ariz. Const., Art. XXVIII, §§ 1(1), 1(2). Participants in the federal litigation, proceeding without benefit of the views of the Arizona Supreme Court, expressed diverse opinions on the meaning of the amendment. ...


The Ninth Circuit had no warrant to proceed as it did. The case had lost the essential elements of a justiciable controversy and should not have been retained for adjudication on the merits by the Court of Appeals. We therefore vacate the Ninth Circuit's judgment, and remand the case to that court with directions that the action be dismissed by the District Court. We express no view on the correct interpretation of Article XXVIII or on the measure's constitutionality.[9]

Furthermore, the court ruled Yniguez's complaint moot given that she resigned seven years before this decision.[10]

Subsequent developments

In 1999, the Supreme Court declined to hear another appeal by Arizonans for Official English in a case in which the Arizona Supreme Court overturned Proposition 106.[3]

In 2006, Arizona voters passed Proposition 103 with 74% of the vote,[11][12] requiring "all official actions of the government be conducted in English" with exceptions for certain duties.[13]

gollark: Besides, how would you even implement kidnapping? We have doors. It would be nontrivial to bypass them.
gollark: I'm sure you'd like to think so.
gollark: Kidnapping me is especially mean.
gollark: Unless you interpret me bringing it up as me secretly trying to manipulate you into considering it, but that would be silly.
gollark: Why would I be there?

See also

References
  1. Arizonans for Official English v. Arizona, 520 U.S. 43 (1996).
  2. "AZ-1988-Proposition 106 (Arizonans for Official English)". Ourcampaigns.com. Retrieved January 31, 2012.
  3. Greenhouse, Linda (January 12, 1999). "Supreme Court Roundup; Appeal to Save English-Only Law Fails". The New York Times. Retrieved January 26, 2012.
  4. Yniguez v. Mofford, 730 F. Supp. 309 (D. Ariz. 1990).
  5. Barringer, Felicity (February 8, 1990). "Judge Nullifies Law Mandating Use of English". The New York Times. Retrieved January 26, 2012.
  6. Yniguez v. Arizona, 939 F.2d 727 (9th Cir. 1991).
  7. Reuters staff report (December 9, 1994). "Court Strikes Language Law". The New York Times.
  8. Greenhouse, Linda (March 26, 1996). "Supreme Court Roundup;Justices to Review Effort to Make English Official Language". The New York Times. Retrieved January 26, 2012.
  9. Arizonans for Official English, 520 U.S. at 48-49.
  10. Greenhouse, Lidna (March 4, 1997). "Justices Set Aside Reversal of 'English Only' Measure". The New York Times. Retrieved January 31, 2012.
  11. McCombs, Brady (November 8, 2006). "Anti-illegal immigrant propositions pass handily". Arizona Daily Star. Archived from the original on November 15, 2006.
  12. "Proposition 103: English as the official language". Arizona Secretary of State. November 28, 2006. Archived from the original on November 1, 2011. Retrieved August 17, 2012.
  13. "Proposition 103 (2006)". Arizona Secretary of State. Archived from the original on December 27, 2011. Retrieved January 31, 2012.
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