Summary of Memphis Community School District v. Stachura, U.S. Supreme Court (1986)
Cause of action: The following is a tort action for damages as the result of an unfounded suspension by the school board.
Procedural History: Sued in district court for those damages, and the judge instructed the jury that if they find for Stachura, that they should determine damages by calculating not only in- and out-of-pocket costs related to his suspension, but in addition, there should be a determinable amount based on what the jurors thought a 1st amendment violation would be worth. Jury found both compensatory damages and punitive damages for respondent, and the case was appealed all the way up to the Court, which reversed and remanded.
Facts: When a teacher was suspended for allegedly showing sexually explicit photos of his wife when she pregnant to his students, which was overly exaggerated. Despite his eventual reinstatement, respondent sued petitioner for damages resulting from his time off from work, and for losses sustained in violating his 1st amendment rights.
Issue(s): Under rules of civil procedure, may a judge instruct a jury, in their deliberation regarding a tort claim, that damages are to be not only decided on issues of out-of-pocket losses, but as a result of the significance of the constitutional amendment which was violated?
Court’s Rationale/Reasoning: The purpose of compensatory damages is to restore the plaintiff for expenses related to the cause of action, not to make a guess on what other damages there might have been. There are situations where a jury must decide on an alternative amount in presumed damages cases. The instructions at issue in this case did not serve in the purpose of substituting ordinary compensation, but instead called the jury to measure damages based on a subjective evaluation of the importance of particular constitutional values.
Since such damages are wholly divorced from any compensatory purpose, they cannot be justified as presumed damages. Moreover, no rough substitute for compensatory damages was required in this case, since the jury was fully authorized to compensate the respondent for both monetary and nonmonetary harms caused by petitioners’ conduct.
Rule: §1983 provides compensatory damages “for actual harm ordinarily (that) ordinarily suffice to deter constitutional violations.”
Holding: No. Damages based on the abstract “value” or “importance” of constitutional rights are not a permissible element of compensatory damages in such cases.
Concurring (Marshall, with Brennan, Blackmun, and Stevens): Sometimes there can be a constitutional violation so great that compensatory damages may needed (like in Carey, involving a due process violation, but it has to be a clear-cut right that is violated for the rule to kick in). The instructions were inappropriate b/c the jury could not adequately focus on PL’s actual damages. However, such a stance on damages as a whole would compromise the values held in Carey (tayloring the damages according to the interests protected by the right).