Carey v. Piphus
435 U.S. 247 (1978)
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Rule of Law:
A plaintiff in an action under 42 U.S.C. § 1983 for a violation of procedural due process must prove actual injury caused by the deprivation of due process itself to recover substantial compensatory damages. In the absence of such proof, the plaintiff is entitled only to nominal damages.
Facts:
- Jarius Piphus, a high school freshman, was seen by his principal passing an irregularly shaped cigarette that smelled of marijuana.
- Without a hearing to determine if he had been smoking marijuana, the principal suspended Piphus for 20 days for violating the school's anti-drug rule.
- Silas Brisco, a sixth-grader, wore a small earring to school in violation of a rule intended to curb gang activity.
- Brisco asserted the earring was a symbol of black pride, but he was suspended for 20 days without a hearing after he refused to remove it.
- Subsequent meetings held for Piphus were to explain the reasons for the suspension, not to adjudicate his guilt or innocence.
Procedural Posture:
- Jarius Piphus and Silas Brisco filed separate lawsuits against school officials in the U.S. District Court, which were consolidated.
- The District Court held that both students had been suspended without procedural due process.
- The District Court declined to award damages, finding the students had put no evidence in the record to quantify their injuries, and dismissed the complaints.
- The students (respondents) appealed to the U.S. Court of Appeals for the Seventh Circuit.
- The Court of Appeals reversed, holding that the students were entitled to recover substantial non-punitive damages for the denial of due process itself, even if their suspensions were justified and they did not prove any individualized injury.
- The school officials (petitioners) successfully petitioned the U.S. Supreme Court for a writ of certiorari.
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Issue:
In an action under 42 U.S.C. § 1983, does a violation of procedural due process, by itself, entitle a plaintiff to substantial compensatory damages without proof of actual injury?
Opinions:
Majority - Mr. Justice Powell
No. A violation of procedural due process does not, by itself, entitle a plaintiff to substantial compensatory damages without proof of actual injury. The purpose of damages under § 1983 is compensatory, mirroring common-law tort principles that require proof of injury and causation. Procedural due process rights are intended to protect individuals from the mistaken or unjustified deprivation of life, liberty, or property, not from the deprivation itself. Therefore, to recover substantial damages, a plaintiff must prove an actual injury, such as mental or emotional distress, that was specifically caused by the denial of process rather than by the underlying, and potentially justified, deprivation. If no actual injury is proven, the plaintiff is only entitled to recover nominal damages, not to exceed one dollar, to vindicate the 'absolute' right to procedural due process.
Analysis:
This decision establishes a critical limitation on damages in procedural due process cases under § 1983. It rejects the theory that a constitutional violation is inherently injurious and compensable with substantial damages. By tethering recovery to traditional tort principles of causation and actual harm, the Court made it significantly more difficult for plaintiffs to recover large damage awards. This precedent forces plaintiffs to prove a concrete injury (like emotional distress) and, more difficultly, to causally link that injury to the procedural defect itself, separate from any distress caused by the underlying (and possibly justified) disciplinary action.
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