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ABA Division for Public Education

Cases of Interest to the School Community
2000–2001 Term

Federalism

Alexander v. Sandoval, No. 99-1908 (Argued Jan. 16, 2001)

Issue: "English Only" Laws
Does Title VI of the Civil Rights Act of 1964 authorize private individuals to challenge a state's requirement that tests be given in English?

Case: Alabama offers its written driver’s license exams in English only. The plaintiffs in this case successfully challenged the state policy in a class-action lawsuit on the grounds that the English-only requirement had a discriminatory impact on foreign-born drivers. The Eleventh Circuit sided with the plaintiffs, saying that the law has the effect of discriminating on the basis of race or national origin. Before the Supreme Court, Alabama argued, among other things, that the states' sovereign immunity should protect them from suits brought by private citizens wishing to allege that a state agency has administered a federal grant in a discriminatory manner.

Decision: On April 24, the Court sided with the state, voting 5–4 that private individuals may not sue to enforce the so-called "disparate-impact" regulations promulgated under Title VI of the Civil Rights Act of 1964.

Read the Eleventh Circuit Court of Appeals' opinion that such lawsuits are not barred by the Eleventh Amendment.

Read the Eleventh Amendment.

Read the state of Alabama's brief defending its English-only laws.

Read the brief of Martha Sandoval, who sued the state because its English-only law prevented non-English-speaking residents from passing the Alabama driver's license test.

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