477 U.S. 299 (1986), 85-410, Memphis Community School District v. Stachura

Docket Nº:No. 85-410
Citation:477 U.S. 299, 106 S.Ct. 2537, 91 L.Ed.2d 249, 54 U.S.L.W. 4771
Party Name:Memphis Community School District v. Stachura
Case Date:June 25, 1986
Court:United States Supreme Court

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477 U.S. 299 (1986)

106 S.Ct. 2537, 91 L.Ed.2d 249, 54 U.S.L.W. 4771

Memphis Community School District



No. 85-410

United States Supreme Court

June 25, 1986

Argued April 2, 1986




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 [106 S.Ct. 2539] 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

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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.

POWELL, J., lead opinion

JUSTICE POWELL delivered the opinion of the Court.

This case requires us to decide whether 42 U.S.C. § 1983 authorizes an award of compensatory damages based on the factfinder's assessment of the value or importance of a substantive constitutional right.


Respondent Edward Stachura is a tenured teacher in the Memphis, Michigan, public schools. When the events that led to this case occurred, respondent taught seventh-grade life science, using a textbook that had been approved by the School Board. The textbook included a chapter on human reproduction. During the 1978-1979 school year, respondent spent six weeks on this chapter. As part of their instruction, students were shown pictures of respondent's wife during

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her pregnancy. Respondent also showed the students two films concerning human growth and sexuality. These films were provided by the County Health Department, and the Principal of respondent's school had approved their use. Both films had been shown in past school years without incident.

After the showing of the pictures and the films, a number of parents complained to school officials about respondent's teaching methods. These complaints, which appear to have been based largely on inaccurate rumors about the allegedly sexually explicit nature of the pictures and films, [106 S.Ct. 2540] were discussed at an open School Board meeting held on April 23, 1979. Following the advice of the School Superintendent, respondent did not attend the meeting, during which a number of parents expressed the view that respondent should not be allowed to teach in the Memphis school system.1 The day after the meeting, respondent was suspended with pay. The School Board later confirmed the suspension, and notified respondent that an "administration evaluation" of his teaching methods was underway. No such evaluation was ever made. Respondent was reinstated the next fall, after filing this lawsuit.

Respondent sued the School District, the Board of Education, various Board members and school administrators, and two parents who had participated in the April 23 School Board meeting. The complaint alleged that respondent's suspension deprived him of both liberty and property without due process of law and violated his First Amendment right to

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academic freedom. Respondent sought compensatory and punitive damages under 42 U.S.C. § 1983 for these constitutional violations.

At the close of trial on these claims, the District Court instructed the jury as to the law governing the asserted bases for liability. Turning to damages, the court instructed the jury that, on finding liability, it should award a sufficient amount to compensate respondent for the injury caused by petitioners' unlawful actions:

You should consider in this regard any lost earnings; loss of earning capacity; out-of-pocket expenses; and any mental anguish or emotional distress that you find the Plaintiff to have suffered as a result of conduct by the Defendants depriving him of his civil rights.

App. 94. In addition to this instruction on the standard elements of compensatory damages, the court explained that punitive damages could be awarded, and described the standards governing punitive awards.2 Finally, at respondent's request and over petitioners' objection, the court charged that damages also could be awarded based on the value or importance of the constitutional rights that were violated:

If you find that the Plaintiff has been deprived of a Constitutional right, you may award damages to compensate him for the deprivation. Damages for this type of injury are more difficult to measure than damages for a physical injury or injury to one's property. There are no medical bills or other expenses by which you can judge how much compensation is appropriate. In one sense, no monetary value we place upon Constitutional rights can measure their importance in our society or compensate a citizen adequately for their deprivation. However, just because these rights are not capable of

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precise evaluation does not mean that an appropriate monetary amount should not be awarded.

The precise value you place upon any Constitutional right which you find was denied to Plaintiff is within your discretion. You may wish to consider the importance of the right in our system of government, the role which this right has played in the history of our republic, [and] the significance of the right in the context of the activities which the Plaintiff was engaged in at the time of the violation of the right.

Id. at 96. The jury found petitioners liable,3 and awarded a total of $275,000 in compensatory damages and $46,000 in punitive damages.4 The District Court entered judgment notwithstanding the verdict as to one of the defendants, reducing the total award to $266,750 in compensatory damages and $36,000 in punitive damages.

In an opinion devoted primarily to liability issues, the Court of Appeals for the Sixth Circuit affirmed, holding that respondent's suspension had violated both procedural due process and the First Amendment. Stachura v. Truszkowski, 763 F.2d 211 (1985). Responding to petitioners' contention that the District Court improperly authorized damages based solely on the value of constitutional rights, the court noted only that

there was ample proof of actual injury to plaintiff Stachura both in his effective discharge . . . and by the damage to his reputation and to his professional career as a teacher. Contrary to the situation in Carey v. Piphus, 435 U.S. 247 (1978) . . . there was proof from which the jury

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could have found, as it did, actual and important damages.

Id. at 214.

We granted certiorari limited to the question whether the Court of Appeals erred in affirming the damages award in the light of the District Court's instructions that authorized not only compensatory and punitive damages, but also damages for the deprivation of "any constitutional right."5 474 U.S. 918 (1985). We reverse, and remand for a new trial limited to the issue of compensatory damages.


Petitioners challenge the jury instructions authorizing damages for violation of constitutional rights on the ground that those instructions permitted the jury to award damages based on its own unguided estimation of the value of such rights.6 Respondent disagrees with this characterization of

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the jury instructions, contending that the compensatory damages instructions, taken as a whole, focused solely [106 S.Ct. 2542] on respondent's injury, and not on the abstract value of the rights he asserted.

We believe petitioners more accurately characterize the instructions. The damages instructions were divided into three distinct segments: (i) compensatory damages for harm to respondent, (ii) punitive damages, and (iii) additional...

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