FEDERALCourt of Appeals for the Ninth Circuit
2003

Carroll v. Nakatani

342 F.3d 934Court of Appeals for the Ninth Circuit • Decided 2003Enforced
FLAGSHIPFlow-DownCited 484 times

HOLDING

Two non-Hawaiian residents challenged Hawaii's race-based benefit programs that reserved certain government benefits and homestead leases for Native Hawaiians. The Ninth Circuit Court of Appeals dismissed their lawsuit, ruling they lacked legal standing because they couldn't prove they were personally denied benefits or that joining the federal government as a party would fix the problem. For subcontractors, this means challenges to government benefit programs require direct personal injury and proper parties in the lawsuit.

KEY FINDINGS

Flow-Down

To challenge a government benefit program in court, you must prove you were personally denied a benefit—general complaints about unfair rules aren't enough

FULL COURT OPINION