In the 2000 case of James Alexander, Director, Alabama Department of Public Safety, et al. v. Martha Sandoval, the U.S Supreme Court ruled that there is no private right to sue under Title VI of the Civil Rights Act of 1964 for disparate impact discrimination. The plaintiff, Martha Sandoval - a non-English speaking Hispanic woman - sued the Alabama Department of Public Safety after it implemented an English-only policy for driver's license exams which she claimed was discriminatory against non-English speakers and violated her rights under Title VI. However, in a 5-4 decision led by Justice Antonin Scalia on behalf of majority court held that while federal agencies could enforce regulations prohibiting actions with discriminatory effects under Title VI; individuals did not have standing to bring such suits themselves as Congress had not explicitly provided this right within legislation.

In the dissenting opinion for Alexander v. Sandoval, Justice Stevens argued that Title VI of the Civil Rights Act should be interpreted to allow private individuals to sue state entities for policies that have a discriminatory impact, even if there is no proof of intentional discrimination. He contended that this interpretation was consistent with past Supreme Court decisions and Congressional intent when passing the law. Furthermore, he believed it was necessary to effectively combat systemic racism and ensure equal opportunity for all citizens regardless of race or national origin. The majority's decision not allowing such lawsuits would undermine these goals by making it more difficult to challenge discriminatory practices in court.