Carey v. Piphus

Brief Fact Summary.

Plaintiffs sued Defendants under 42 U.S.C. § 1983 for depriving them of procedural due process when they were suspended from school.

Synopsis of Rule of Law.

Without proof of injury, plaintiffs are only entitled to nominal damages in a lawsuit for procedural due process violations.

Facts.

Jarius Piphus (Plaintiff) and his friend were suspended for twenty days after being accused of smoking at school without an opportunity to contest the suspension. Plaintiff and his mother filed suit against school officials and school board members (Defendants) under 42 U.S.C. § 1983, seeking declaratory and injunctive relief and actual and punitive damages. At another school, Silas Brisco (Plaintiff) was suspended for twenty days for wearing an earring without an opportunity to contest the suspension. He and his mother filed suit against school officials and school board members (Defendants) under 42 U.S.C. § 1983, seeking declaratory and injunctive relief and actual and punitive damages. The two cases were consolidated in federal court.

Issue.

Must the Plaintiffs provide proof of injury to be awarded substantial damages?

Held.

Yes, without proof of injury the Plaintiffs are entitled only to nominal damages. The case is reversed and remanded.

Discussion.

The Court determined that actual and punitive damages required proof of an injury suffered, even in cases involving the deprivation of constitutional rights. Substantial actual damages should be awarded only to compensate actual injury, and punitive damages should be awarded only to punish malicious conduct. However, even if the lower courts determine that the Plaintiffs were rightfully suspended, they still suffered a deprivation of procedural due process and should be awarded nominal damages.