Alexander v. Sandoval
Citation: 532 U.S. 275 (2001)
Facts
Alabama implemented an English-only policy for driver’s license examinations. Martha Sandoval, a Spanish speaker, sued under Title VI of the Civil Rights Act of 1964 and its implementing regulations, arguing that the policy had a disparate impact on non-English speakers. Title VI itself bans intentional discrimination; the regulations also ban disparate-impact practices.
Issue
Is there a private right of action to enforce federal agency regulations promulgated under Title VI that prohibit disparate-impact discrimination, when Title VI itself only bars intentional discrimination?
Holding
No. The Supreme Court held that there is no implied private right of action to enforce disparate-impact regulations under Title VI. Congress did not intend to create such a right, and private plaintiffs may only sue for intentional discrimination under § 601 of Title VI.
Rule
A private right of action to enforce federal law must be created by Congress, either expressly or by clear implication. Courts will not imply a private right of action from agency regulations alone. The analysis focuses on whether Congress, not the agency, intended to create a private remedy.
Significance
Sandoval is a landmark case limiting implied private rights of action and substantially narrowing the reach of federal civil rights law. It effectively ended private disparate-impact suits under Title VI and signals the Court’s reluctance to imply new causes of action from statutes and regulations.