Juniven Rey S Umadhay LLB-1 LO1

ConLaw 1

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 Courts 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?

Held
No. When a federal courts 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.