James Alexander, Director, Alabama Department of Public Safety, et al. v. Martha Sandoval, Individually and on Behalf of All Others Similarly Situated
The Court decided that a regulation enacted under Title VI of the Civil Rights Act of 1964 did not include a private right of action allowing private lawsuits based on evidence of disparate impact.· AI-written
532 U.S. 275 · No. 99-1908 · 2000 term · Rehnquist Court
Decided Apr 24, 2001 · argued Jan 16, 2001
Judicial power · Standing to sue: private or implied cause of action
Majority opinion: Antonin Scalia
The voteMajorityDissent
5–45 in the majority, 4 in dissent
4 dissents (5–4)
Reversed. James Alexander, Director, Alabama Department of Public Safety, et al. won.
What this ruling means
Reversed: the Supreme Court overturned the decision of the U.S. Court of Appeals, Eleventh Circuit, and its own ruling ends the case.
James Alexander, Director, Alabama Department of Public Safety, et al. was the petitioner, the side that asked the Supreme Court to review the case. “Won” means the Court gave that side the result it asked for.
From the Supreme Court Database. A justice who agreed with the result but not the reasoning counts in the majority.
Summary
The opening of the case’s Wikipedia article: what the case was about and what the Court held.
Alexander v. Sandoval, 532 U.S. 275 (2001), was a Supreme Court of the United States decision that a regulation enacted under Title VI of the Civil Rights Act of 1964 did not include a private right of action to allow private lawsuits based on evidence of disparate impact.
Data notes
The text is Wikipedia’s (CC BY-SA 4.0), matched to the case by its citation, docket number or name and year, and is not checked against the opinion. The site keeps the article’s opening section, ending on its last full sentence. The one-sentence summary under the title is the Decisions list’s: Wikipedia’s own ruling sentence, or, tagged “AI-written”, one Claude wrote from this opening.
How the justices voted
Each justice who took part, placed by their Martin–Quinn ideology score for the 2000 term. Filled: the 5 in the majority. Hollow: the 4 in dissent. Colour is the party of the president who appointed them.
Majority(5)
Antonin ScaliaWrote the majority opinion
Sandra O'ConnorJoined the majority
Anthony KennedyJoined the majority
William RehnquistJoined the majority
Clarence ThomasJoined the majority
Dissent(4)
John StevensWrote a dissent
Ruth GinsburgJoined a dissent
Stephen BreyerJoined a dissent
David SouterJoined a dissent
Data notes
Each justice’s vote and what they wrote are from the justice-centered file of the Supreme Court Database. “Wrote a concurrence” means the justice sided with the majority and wrote separately; a justice who dissented in part is counted on the side they took overall. A justice who wrote nothing is listed as joining their side.
Positions are each justice’s Martin–Quinn score for the case’s term, the same scores as the Ideology page: negative is more liberal, positive more conservative. A score sums up a justice’s votes across the whole term, so it says where they usually sit, not why they voted as they did here. The median line is the Court’s median justice that term.
The parties
Who brought the case to the Court, who answered it, and how it got there.
- Petitioner
- James Alexander, Director, Alabama Department of Public Safety, et al.Governmental official, or an official of an agency established under an interstate compact (Alabama)
- Respondent
- Martha Sandoval, Individually and on Behalf of All Others Similarly SituatedAlien, person subject to a denaturalization proceeding, or one whose citizenship is revoked
- Reached the Court by
- Certiorari (the Court chose to hear it)
Data notes
The names are the two sides of the case’s title. The description under each is the Supreme Court Database’s category for that party, in its own wording. The petitioner is the side that asked the Supreme Court to review the decision below. “Why it was taken” appears only when the majority opinion says lower courts disagreed or were unsure about the question; reasons that would fit any case (“to resolve the question presented”, “an important question”) are left out.
The law at issue
The law the Court was asked to apply, and the kind of power it used to decide.
- Provision
- Civil Rights Act of 1964 (Title VI)
- Kind of law
- Federal Statute
- Decided by
- Statutory construction
Data notes
The Supreme Court Database codes the main constitutional provision, statute or court rule each case turned on, and the basis of the decision: judicial review of a federal or state law, interpreting a statute, supervising the lower courts, and so on. A case can rest on more than one. “Overruled” counts only where the majority opinion says so.
Timeline
What happened at the Court and how the case got there, newest first.
- Apr 24, 2001DecidedDecided · Decided 5–4: reversed. James Alexander, Director, Alabama Department of Public Safety, et al. won.
- Jan 16, 2001ArguedArgued · Oral argument before the Court.
- Not datedTaken upTaken up · The Supreme Court agreed to hear the case (certiorari).
- Not datedCourt belowCourt below · Decided by the U.S. Court of Appeals, Eleventh Circuit: affirmed.
- Not datedBeganBegan · The case began in the Alabama Middle U.S. District Court.
Data notes
From the Supreme Court Database: the court the case began in, the court whose decision the Supreme Court reviewed and what that court did, how the case came to the Court, and the dates of argument and decision. The database does not date the steps in the lower courts. Court names are the database’s.
Other decisions on the same issue
12 other argued cases since 1946 on standing to sue: private or implied cause of action, newest first.
- Armstrong v. Exceptional Child Center, Inc.575 U.S. 320Mar 31, 2015 · 575 U.S. 320Judicial power5–45–4 band
- Linda J. Blessing, Director, Arizona Department of Economic Security v. Cathy Freestone, etc., et al.520 U.S. 329Apr 21, 1997 · 520 U.S. 329Judicial power9–0Unanimous band
- Alan Meghrig, et al. v. KFC Western, Inc.516 U.S. 479Mar 19, 1996 · 516 U.S. 479Judicial power9–0Unanimous band
- United States v. California and California State Board of Equalization507 U.S. 746Apr 26, 1993 · 507 U.S. 746Judicial power9–0Unanimous band
- Sue Suter, et al. v. Artist M., et al.503 U.S. 347Mar 25, 1992 · 503 U.S. 347Judicial power7–27–2 band
- Karahalios v. National Federation of Federal Employees, Local 1263489 U.S. 527Mar 6, 1989 · 489 U.S. 527Judicial power9–0Unanimous band
- Thompson v. Thompson, aka Clay484 U.S. 174Jan 12, 1988 · 484 U.S. 174Judicial power8–0Unanimous band
- Wright et al. v. City of Roanoke Redevelopment and Housing Authority479 U.S. 418Jan 14, 1987 · 479 U.S. 418Judicial power5–45–4 band
- Merrill Lynch, Pierce, Fenner & Smith, Inc. v. Curran et al.456 U.S. 353May 3, 1982 · 456 U.S. 353Judicial power5–45–4 band
- California et al. v. Sierra Club et al.451 U.S. 287Apr 28, 1981 · 451 U.S. 287Judicial power9–0Unanimous band
- Universities Research Assn., Inc. v. Coutu450 U.S. 754Apr 6, 1981 · 450 U.S. 754Judicial power9–0Unanimous band
- Cannon v. University of Chicago et al.441 U.S. 677May 14, 1979 · 441 U.S. 677Judicial power6–36–3 band
Data notes
Every other orally argued case with a clear vote, from the 1946 term on, that the Supreme Court Database files under the same issue as this one. The database gives each case one issue from a list of about 270 (abortion, search and seizure of vehicles, the death penalty, and so on), whatever law it turned on.
Official record
Read the full opinion on Justia, the argument audio on Oyez and Wikipedia. Case data from the Supreme Court Database, Version 2026 Release 01, through the 2025 term.