Number: RL31077 Title: Private Actions to Sue for Civil Rights Violations in Federally Assisted Programs After Alexander v. Sandoval Authors: Charles V. Dale, American Law Division Abstract: In Alexander v. Sandoval, a narrow 5 to 4 majority of the U.S. Supreme Court ruled that private individuals may not sue state agencies under Title VI of the 1964 Civil Rights Act over claims of unintentional or so-called "disparate impact" discrimination. At least for now, "disparate impact" rules -- like those mandating language assistance for non-English proficient clients of federally finance programs - may still be enforced by the government, just not by private litigants. But given the lengths to which the Court went to address an issue on which the federal appellate courts were substantially in agreement, Sandoval may augur future perils for substantive agency rules condemning disparate impact under Title VI. Pages: 7 Date: Updated August 9, 2001