Memphis Community School Dist. v. Stachura

Brief Fact Summary. After a seventh grade teacher (Respondent) was suspended for showing sexually explicit materials in his life-science course, he brought suit alleging he was deprived of liberty and property without due process.

Synopsis of Rule of Law. When dealing with the violation of constitutional rights, compensatory damages are available for measurable harms suffered.

Facts. Respondent was a seventh grade teacher in Petitioner’s school. After several parents complained about his teaching methods, Respondent was suspended. Although he was later reinstated, Respondent brought suit alleging deprivation of his civil rights. The district court and court of appeals found the Petitioner liable and awarded Respondent compensatory and punitive damages. Petitioner appealed, and the Supreme Court of the United States granted certiorari to consider whether damages were appropriate when they were awarded for the “deprivation of any constitutional right.”

Issue. Whether damages are appropriate whenever a constitutional right is violated?

Held. Reversed and Remanded.
* The Supreme Court reversed and remanded for a new trial, strictly to deal with the issue of compensatory damages. The Court found that compensatory damages may include pecuniary losses, as well as injuries such as impairment of reputation, but they could not necessarily be for the “deprivation of a constitutional right,” without a showing that harm was suffered for that deprivation.
Concurrence. Justice Marshall concurred, noting that in some cases, the violation of a constitutional right may cause harm sufficient to allow reparation.

Discussion. Compensatory damages are available when a civil right, such as life, liberty or property, has been violated. However, without showing that an injury has occurred, the deprivation of a constitutional right, alone, may not lead to a separate class of da.