Eric Garner was not the first American to be choked by the police, and he will not be the last, thanks to legal rules that prevent victims of police violence from asking federal courts to help stop deadly practices.

The 1983 case City of Los Angeles v. Lyons vividly illustrates the problem. That case also involved an African-American man choked by the police without provocation after he was stopped for a minor offense—a burned-out taillight. Unlike Mr. Garner, Adolph Lyons survived the chokehold. He then filed a federal lawsuit, asking the city to compensate him for his injuries. But he wanted more than just money. He also asked the court to prevent the Los Angeles Police Department from using chokeholds in the future. The trial court ordered the L.A.P.D. to stop using chokeholds unless an officer was threatened with death or serious injury, and to institute better training, reporting and record-keeping.

The Supreme Court overturned this order by one vote. The court explained that Mr. Lyons would have needed to prove that he personally was likely to be choked again in order for his lawsuit to be a vehicle for systemic reform. Without that, he could win compensation only for past injuries.

Shakeer Rahman and Sam Barr, “Eric Garner and the Legal Rules that Enable Police Violence”