Law School Case Brief
Memphis Cmty. Sch. Dist. v. Stachura - 477 U.S. 299, 106 S. Ct. 2537 (1986)
Punitive damages aside, damages in tort cases are designed to provide compensation for the injury caused to plaintiff by defendant's breach of duty. To that end, compensatory damages may include not only out-of-pocket loss and other monetary harms, but also such injuries as impairment of reputation, personal humiliation, and mental anguish and suffering. Deterrence is also an important purpose of this system, but it operates through the mechanism of damages that are compensatory -- damages grounded in determinations of plaintiffs' actual losses. Congress adopted this common-law system of recovery when it established liability for "constitutional torts." Consequently, "the basic purpose" of 42 U.S.C.S. § 1983 damages is to compensate persons for injuries that are caused by the deprivation of constitutional rights.
Respondent Edward Stachura, 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 Stachura 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.
Does 42 U. S. C. § 1983 authorize an award of compensatory damages based on the factfinder's assessment of the value or importance of a substantive constitutional right?
The Court held that damages based on the value or importance of constitutional rights were not authorized by § 1983 because they were not truly compensatory. In order for a plaintiff to obtain compensatory damages in a § 1983 action, he had to show actual injury as a result of the deprivation of his constitutional rights. Because of the general nature of the verdict, there was no way for the Court to determine what portion of the compensatory damages award was attributable to the teacher's actual injury and what was the result of the erroneous jury instruction. Thus, a retrial was ordered on the limited issue of compensatory damages.
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