Memphis Comm. Sch. Dist. v. Stachura
Annotate this Case
477 U.S. 299 (1986)
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U.S. Supreme Court
Memphis Comm. Sch. Dist. v. Stachura, 477 U.S. 299 (1986)
Memphis Community School District v. Stachura
Argued April 2, 1986
Decided June 25, 1986
477 U.S. 299
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 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. 477 U. S. 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, 435 U. S. 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. 477 U. S. 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. 477 U. S. 310-312.
(c) The erroneous instructions were not harmless error where the verdict did not specify how much of the compensatory damages was designed
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. 477 U. S. 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. 477 U. S. 313. MARSHALL, J., filed an opinion concurring in the judgment, in which BRENNAN, BLACKMUN, and STEVENS, JJ., joined, post, p. 477 U. S. 313.