Case Summary: Alexander v. Sandoval
532 U.S. 275 (2001)
In 1990, Alabama added an amendment to its state's constitution which made English the state's official language. As a result, the state's Director of the Department of Public Safety issued a new rule that the state's driver’s license exam would be offered only in English. Martha Sandoval sued, arguing that the state policy of English only driver's licenses violated Title VI of the Civil Rights Act of 1964, which prohibits discrimination based on race, color or national origin in federally funded programs. Sandoval claimed that the English-only rule for driver's licenses had a disproportionately negative impact on people based on their national origin.
In Alexander v. Sandoval, the Supreme Court held that while Title VI does prohibit practices with a discriminatory impact, individuals cannot sue to stop those practices unless they can also show discriminatory intent. According to the Court, only the government can combat discrimination under Title VI based on a disparate impact theory.
The Court's ruling in Sandoval contradicts more than 30 years of settled law, making it much more difficult for victims of discrimination in federally funded programs to vindicate their rights.
