Wood v. Strickland

Supreme Court of United States
420 U.S. 308 (1975)

ELI5:

Rule of Law:

A school board member is not immune from liability for damages under 42 U.S.C. § 1983 if they knew or reasonably should have known that their action would violate a student's clearly established constitutional rights, or if they took the action with the malicious intention to cause a deprivation of constitutional rights or other injury.

Facts:

Respondents Peggy Strickland and Virginia Crain, 16-year-old high school students, were responsible for providing refreshments at an extracurricular school meeting attended by parents and students.
Finding that punch had not been prepared as planned, the girls agreed to "spike" it.
They drove across the state line, purchased two bottles of "Right Time" malt liquor and several bottles of soft drink.
The girls mixed the beverages into a punch and returned to school.
Although they had second thoughts, the punch was served at the meeting.
Ten days later, a teacher questioned the girls, and they eventually admitted their role to the principal, P. T. Waller.
Waller suspended the girls from school for two weeks, subject to a decision by the school board.
The school board met that night and, after receiving reports and withdrawing initial recommendations for leniency, voted to expel the girls for the remainder of the semester, a period of about three months.

Procedural Posture:

Peggy Strickland and Virginia Crain sued members of the school board and school administrators in the U.S. District Court for the Western District of Arkansas under 42 U.S.C. § 1983.
The jury failed to reach a verdict, resulting in a mistrial.
The District Court directed a verdict in favor of the petitioners (school board members), ruling they were immune from damages absent proof of malice, which it found lacking.
Strickland and Crain (as appellants) appealed to the U.S. Court of Appeals for the Eighth Circuit.
The Court of Appeals reversed the District Court's judgment, finding a violation of substantive due process, and remanded for a new trial on damages and for injunctive relief.
The school board members (as petitioners) successfully petitioned the U.S. Supreme Court for a writ of certiorari.

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Issue:

Is a school board member immune from liability for damages under 42 U.S.C. § 1983 for a disciplinary action if the member acted without malicious intent but in ignorance or disregard of a student's settled, indisputable constitutional rights?

Opinions:

Majority - Mr. Justice White

No. A school board member is not immune from liability for damages under § 1983 if they knew or reasonably should have known that their action violated a student's constitutional rights, or if they acted with malicious intention. The Court held that qualified immunity for school officials contains both a subjective and an objective element. While officials must act sincerely and with a belief they are doing right (subjective), they cannot justify violating a student's rights through ignorance or disregard of settled, indisputable law (objective). Relying on precedents like Scheuer v. Rhodes, the court reasoned that public policy requires a balance between protecting officials from frivolous lawsuits and providing a remedy for students whose constitutional rights have been violated. An official must be held to a standard of conduct based on knowledge of basic, unquestioned constitutional rights. However, the court also reversed the Court of Appeals' finding of a substantive due process violation, holding that the lower court had misinterpreted the school's regulation against "intoxicating beverages" and that there was evidence to support the board's disciplinary action under a proper construction of the rule.

Concurring-in-part-and-dissenting-in-part - Mr. Justice Powell

Yes, officials should be immune under a less stringent standard. The standard for qualified immunity imposed by the majority is too harsh and holds lay school officials to a higher standard of legal knowledge than that required of other government executives. The dissent argues that the new standard, requiring knowledge of 'settled, indisputable law' and 'unquestioned constitutional rights,' is unrealistic, as constitutional law is complex and often evolving, a fact demonstrated by the Supreme Court's own divided opinions. The correct standard, articulated in Scheuer v. Rhodes, should be whether the official acted reasonably and in good faith based on the circumstances as they appeared at the time. The majority's holding creates a significant risk of personal liability that may deter qualified citizens from serving on school boards.

Analysis:

This case established the modern, two-part standard for qualified immunity for public officials, which includes both a subjective and an objective component. The decision significantly altered the 'good faith' defense by adding an objective test: officials are now accountable not just for their intentions, but also for what they 'reasonably should have known' about clearly established constitutional law. This objective prong, later refined in Harlow v. Fitzgerald, makes it more difficult for officials to claim immunity based on ignorance of the law. The ruling thereby strengthened 42 U.S.C. § 1983 as a vehicle for citizens to seek redress for constitutional violations by state actors, while still affording officials protection from liability for good-faith mistakes in judgment.

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