E.15 DeFunis v.

Odegaard
416 U.S. 312 | 1974 | Per Curiam
CARLA | Judiciary – Powers – Requisites
Case Summary: Marco DeFunis, Jr. applied for admission as a first-year student at the University
of Washington Law School, a state-operated institution. Upon his application for admission was
denied, he brought suit in a Washington trial court claiming that the admissions committee
procedures were racially discriminatory.

Doctrine: Mootness ends a case when the parties no longer have opposing legal interests or any
concrete or definite controversy between them.

Petitioner: Marco DeFunis, Jr.

Respondent/s: Odegaard as the State Education Official and, University of Washington Law School
Admissions Committee

Facts:
DeFunis was denied from first year admission at the University of Washington Law School, a state-
operated institution. Upon learning that he was denied from admission, DeFunis sued a state
education official, Odegaard, as well as the law school admissions committee on the basis that it had
violated the Equal Protection Clause because its policies and procedures had resulted in
discrimination against him because of his race. On the other hand, the size of the incoming first-year
class was to be limited to 150 persons, and the Law School received some 1,600 applications for
these 150 places.

DeFunis brought the suit on behalf of himself alone, and not as the representative of any class. He
sought a mandatory injunction from the trial court that would compel Odegaard to grant him admission
into the first-year law school class because his application had been unconstitutionally denied.
Consequently, he prevailed in the lower court and was admitted to the law school, pending Odegaard's
appeal.

DeFunis was in his third year and final year when the Court granted his petition. Further, the University
has agreed to let him graduate upon completion of his last year. The state Supreme Court eventually
ruled that the law school admissions policy was constitutional.

Issue/s: Whether or not an actual controversy exists between the parties. NO

Held:
The case was rendered moot as Petitioner will complete his third year in law school and be awarded
his J.D. degree at the end of the 1973-74 academic year regardless of the outcome of the appeal. This
was followed by the counsel for the respondents who made clear that the Law School will not in any
way seek to abrogate Petitioners’ registration for his final quarter in law school.

With the case being moot, the Court cannot consider reviewing the substantive constitutional issues
consistently with the limitations of Art. III of the Constitution.

Ruling:
Art. III of the Constitution, consider the substantive constitutional issues tendered by the
parties. Accordingly, the judgment of the Supreme Court of Washington is vacated, and the cause is
remanded for such proceedings as by that court may be deemed appropriate.
(a) Mootness here does not depend upon a "voluntary cessation" of the school's admissions practices,
but upon the simple fact that petitioner is in his final term, and the school's fixed policy to permit him
to complete the term.

(b) The case presents no question that is "capable of repetition, yet evading review," since petitioner
will never again have to go through the school's admissions process, and since it does not follow
that the issue petitioner raises will in the future evade review merely because this case did not reach
the Court until the eve of petitioner's graduation.