Alexander v. Sandoval Case Brief

Facts of the Case

As a recipient of federal financial assistance, the Alabama Department of Public Safety (Department), of which petitioner Alexander was the Director, was subject to Title VI of the Civil Rights Act. Section 601 of the statute prohibited discrimination based on race, color, or national origin in covered programs and activities. Section 602 of the same Title authorized federal agencies to effectuate §601 by issuing regulations. The United States Department of Justice (DOJ), in an exercise of this authority, promulgated a regulation forbidding federal funding recipients to utilize criteria or administrative methods having the effect of subjecting individuals to discrimination based on the prohibited grounds. Alabama’s department of public safety accepted grants of federal financial assistance and thus was subject to the restrictions of Title VI. The state of Alabama amended its constitution to make English the official language of Alabama. The department, in response to the amendment and allegedly as a matter of public safety, required that all state driver’s license tests be administered in English. Thereafter, respondent Sandoval, who was an Alabama resident, brought a class action to enjoin the Department’s decision to administer state driver’s license examinations only in English, arguing that it violated the DOJ regulation because it had the effect of subjecting non-English speakers to discrimination based on their national origin. Agreeing, the District Court enjoined the policy and ordered the Department to accommodate non-English speakers. The Eleventh Circuit affirmed. Both courts rejected petitioners’ argument that Title VI did not provide respondent a cause of action to enforce the regulation.




“No. In a 5-4 opinion delivered by Justice Antonin Scalia, the Court held that there is no private right of action to enforce disparate-impact regulations promulgated under Title VI. “Title VI itself directly reaches only instances of intentional discrimination,” wrote Justice Scalia, “[n]either as originally enacted nor as later amended does Title VI display an intent to create a freestanding private right of action to enforce regulations promulgated under [section 602].” Justice John Paul Stevens filed a dissenting opinion, which was join by Justices David H. Souter, Ruth Bader Ginsburg, and Stephen G. Breyer.”

Case Information

Citation: 532 US 275 (2001)
Argued: Jan 16, 2001
Decided: Apr 24, 2001
Case Brief: 2001