Uzuegbunam v. Preczewski
592 U. S. ____ (2021) (2021)
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Rule of Law:
A plaintiff's request for nominal damages for a completed violation of a legal right is sufficient to satisfy the redressability requirement for Article III standing, thereby preventing a case from being dismissed as moot.
Facts:
- Chike Uzuegbunam was a student at Georgia Gwinnett College, a public institution.
- In 2016, while on campus grounds, Uzuegbunam attempted to share his Christian faith by speaking with students and distributing religious literature.
- A campus police officer stopped Uzuegbunam, informing him that campus policy prohibited distributing religious materials outside of two small, designated "free speech expression areas."
- After obtaining a permit to use a designated free speech zone, Uzuegbunam began speaking about his religion.
- A campus police officer again ordered Uzuegbunam to stop, stating that his speech violated a policy against anything that “disturbs the peace and/or comfort of person(s)” because people had complained.
- The officer threatened Uzuegbunam with disciplinary action if he continued.
- Another student, Joseph Bradford, who shared Uzuegbunam’s faith, decided not to speak about his religion due to these events.
Procedural Posture:
- Chike Uzuegbunam and Joseph Bradford sued college officials in the U.S. District Court, seeking nominal damages and injunctive relief.
- After the lawsuit was filed, the college officials changed the challenged speech policies.
- The college officials then filed a motion to dismiss the case as moot.
- The District Court granted the motion to dismiss, holding that the students' claim for nominal damages was insufficient to keep the case alive.
- The students (appellants) appealed to the U.S. Court of Appeals for the Eleventh Circuit.
- The Eleventh Circuit affirmed the district court's dismissal.
- The Supreme Court of the United States granted certiorari to review the Eleventh Circuit's decision.
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Issue:
Does a request for only nominal damages for a completed constitutional violation satisfy the redressability requirement for Article III standing, thereby preventing a case from being dismissed as moot?
Opinions:
Majority - Thomas, J.
Yes. A request for nominal damages by itself can redress a past injury and is sufficient to maintain a live case or controversy under Article III. The Court reasoned that Article III standing is informed by common law tradition, where courts consistently awarded nominal damages for the violation of a legal right, even without proof of actual monetary harm. This historical practice was based on the principle that 'every injury imports a damage,' ensuring that important but non-quantifiable rights (like free speech or voting) could be vindicated in court. The Court rejected the argument that nominal damages are purely symbolic, holding instead that they constitute a concrete remedy on the merits that alters the defendant's behavior toward the plaintiff, thus satisfying the redressability requirement.
Concurring - Kavanaugh, J.
Yes. While agreeing with the majority's historical and precedential analysis, this opinion adds that a defendant should be able to end litigation by accepting the entry of a judgment for nominal damages. This would allow the defendant to avoid a full resolution on the merits, mitigating the concern raised by the dissent that federal courts will be forced to issue advisory opinions.
Dissenting - Roberts, C. J.
No. A request for nominal damages alone cannot save an otherwise moot case from dismissal. Because the students were no longer enrolled and the college had rescinded the challenged policies, the court could grant no 'effectual relief.' An award of one dollar does not remedy any past harm or prevent future injury; it merely represents a judicial declaration that the plaintiff's legal interpretation is correct, which is tantamount to an advisory opinion forbidden by Article III. The majority's reliance on common law is unpersuasive, as those precedents typically involved claims for actual damages or prospective relief, and the historical record is not as clear as the majority suggests. This holding risks a major expansion of the judicial role, requiring courts to issue opinions whenever a plaintiff tacks on a request for a dollar.
Analysis:
This decision resolves a circuit split and clarifies a key aspect of mootness and standing doctrine. It establishes that defendants cannot evade judicial review of allegedly unconstitutional policies simply by revoking the policy after a lawsuit is filed. The ruling is particularly significant for civil rights cases, especially those involving First Amendment speech, where the injury is often difficult to quantify in monetary terms. By affirming that a claim for nominal damages keeps a case alive, the Court ensures that plaintiffs can obtain a judicial ruling on the merits that vindicates their rights and holds government actors accountable for past conduct.
