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Memphis Comm. Sch. Dist. v. Stachura, 477 U.S. 299 (1986)
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General SummaryThis case is from a collection containing the full text of over 16,000 Supreme Court cases from 1793 to the present. The body of Supreme Court decisions are, effectively, the final interpretation of the Constitution. Only an amendment to the Constitution can permanently overturn an interpretation and this has happened only four times in American history.
Memphis Comm. Sch. Dist. v. Stachura, 477 U.S. 299 (1986)
Memphis Community School District v. Stachura No. 85-410 Argued April 2, 1986 Decided June 25, 1986 477 U.S. 299
CERTIORARI TO THE UNITED STATES COURT OF APPEALS FOR
THE SIXTH CIRCUIT
Syllabus
Respondent, a tenured teacher in the Memphis, Michigan, public schools, was suspended following parents’ complaints about his teaching methods in a seventh-grade life science course that included the showing of allegedly sexually explicit pictures and films. While respondent was later reinstated, he, before being reinstated, brought suit in Federal District Court under 42 U.S.C. § 1983 against petitioner School District, Board of Education, Board Members, school administrators, and parents, alleging that his suspension deprived him of liberty and property without due process of law and violated his First Amendment right to academic freedom. He sought both compensatory and punitive damages. The District Court instructed the jury on the standard elements of compensatory and punitive damages and also charged the jury that additional compensatory damages could be awarded based on the value or importance of the constitutional rights that were violated. The jury found petitioners liable, awarding both compensatory and punitive damages. The Court of Appeals affirmed.
Held: Damages based on the abstract "value" or "importance" of constitutional rights are not a permissible element of compensatory damages in § 1983 cases. Pp. 304-313.
(a) The basic purpose of § 1983 damages is "to compensate persons for injuries that are caused by the deprivation of constitutional rights." Carey v. Piphus, 435 U.S. 247, 254. The instructions at issue cannot be squared with Carey, or with the principles of tort damages on which Carey and § 1983 are grounded. Damages measured by the jury’s perception of the abstract "importance" of a constitutional right are not necessary to vindicate the constitutional rights that § 1983 protects, and moreover are an unwieldy tool for ensuring compliance with the Constitution. Pp. 305-310.
(b) Since such damages are wholly divorced from any compensatory purpose, they cannot be justified as presumed damages, which are a substitute for ordinary compensatory damages, not a supplement for an award that fully compensates the alleged injury. Pp. 310-312.
(c) The erroneous instructions were not harmless error where the verdict did not specify how much of the compensatory damages was designed to compensate respondent for his injury and how much reflected the jury’s estimation of the value of the constitutional rights that were infringed. Pp. 312-313.
763 F.2d 211, reversed and remanded.
POWELL, J., delivered the opinion of the Court, in which BURGER, C.J., and BRENNAN, WHITE, REHNQUIST, STEVENS, and O’CONNOR, JJ., joined. BRENNAN and STEVENS, JJ., filed a separate statement, post, p. 313. MARSHALL, J., filed an opinion concurring in the judgment, in which BRENNAN, BLACKMUN, and STEVENS, JJ., joined, post, p. 313.
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Chicago: U.S. Supreme Court, "Syllabus," Memphis Comm. Sch. Dist. v. Stachura, 477 U.S. 299 (1986) in 477 U.S. 299 477 U.S. 300. Original Sources, accessed November 24, 2024, http://originalsources.com/Document.aspx?DocID=QZFEVEQWLDS4ZR6.
MLA: U.S. Supreme Court. "Syllabus." Memphis Comm. Sch. Dist. v. Stachura, 477 U.S. 299 (1986), in 477 U.S. 299, page 477 U.S. 300. Original Sources. 24 Nov. 2024. http://originalsources.com/Document.aspx?DocID=QZFEVEQWLDS4ZR6.
Harvard: U.S. Supreme Court, 'Syllabus' in Memphis Comm. Sch. Dist. v. Stachura, 477 U.S. 299 (1986). cited in 1986, 477 U.S. 299, pp.477 U.S. 300. Original Sources, retrieved 24 November 2024, from http://originalsources.com/Document.aspx?DocID=QZFEVEQWLDS4ZR6.
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