Case Citator › Larry v. Riles

Larry v. Riles

Is it still good law? What later courts have actually done to this case.

Abrogated
Court
Ninth Circuit
Citation
793 F.2d 969
Decided
Confirmed treatments
2
Flagged citations read
17 of 17
Citing cases (total)
17
Treatment dates
2001–2011
Abrogated
A reviewed court treats this case as abrogated by later authority. Larry v. Riles has been abrogated on its holding that private plaintiffs may enforce Title VI disparate impact regulations. Alexander v. Sandoval ended that route to relief; the Supreme Court dissent identified Larry among the decisions recognizing it.
More on how this was screened

The separate holdings on disability education statutes and discriminatory IQ testing are not resolved by Sandoval. A district court also declined to follow a statement in Larry about the burden of proving compliance with Rehabilitation Act regulations. Both confirmed treatments are listed below. All 17 flagged citations have been read.

Every treatment on this page is written from the citing opinion itself, with a verbatim quote, never copied from a commercial citator. A citation flagged by our screen but not shown here was read and found not to weaken this case.

17 later cases cite Larry v. Riles; 17 of those citations sat close to treatment language and were flagged for reading, and all of them have been read. Citations that did not sit near treatment language were not flagged and were not read one by one, so a court that weakened this case without using any of that language would not appear here.

Relying on Larry v. Riles?

This page shows what later courts did to it. Ask about your specific facts and see whether it still carries your argument, with citations you can check.

Treatments

Abrogated

  • The Supreme Court held that private plaintiffs cannot sue to enforce Title VI disparate impact regulations, ending the private enforcement route Larry used for its Title VI ruling.

    Alexander v. Sandoval · Supreme Court of the United States · filed

    It is clear now that the disparate-impact regulations do not simply apply § 601 — since they indeed forbid conduct that § 601 permits — and therefore clear that the private right of action to enforce § 601 does not include a private right to enforce these regulations.
    Read the full opinion on CourtListener →

Declined to follow

  • The Middle District of Alabama expressly refused to follow Larry's statement that a recipient bears the burden of proving compliance with Rehabilitation Act regulations in a suit for compensatory damages.

    H. ex rel. T.H. v. Montgomery County Board of Education · Middle District of Alabama · filed

    Ms. H’s claim that the burden rests with the Board comes from a Ninth Circuit case, Larry P. By Lucille P. v. Riles, 793 F.2d 969 (9th Cir.1984), that states, without citing authority: “[t]he regulations place the burden on the recipient to show it has complied with the requirements [in the regulations.]” Id. at 980. This case involved facts distinguishable from the instant case, and is not binding on this court. To the extent its facts are analogous to those at bar, this court will not follow the quoted statement in this case with respect to a claim for compensatory damages.
    Read the full opinion on CourtListener →

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