Memphis Community School District v. Stachura

Supreme Court of the United States · 1986 · Torts

477 U.S. 299 (1986)

Updated July 23, 2026

TortsSection 1983 damagesConstitutional tortsCompensatory damages42 U.S.C. § 1983constitutional rightsabstract valueactual injury

Facts

Respondent was a tenured public school teacher who was suspended with pay after parents complained about his teaching of a human reproduction chapter and the use of pictures and films approved by school authorities. He sued the school district, board, administrators, and others under § 1983, alleging deprivation of liberty and property without due process and violation of his First Amendment right to academic freedom. The trial court instructed the jury not only on ordinary compensatory damages for lost earnings, expenses, and emotional distress, and on punitive damages, but also that it could award damages based on the value or importance of the constitutional rights violated. The jury returned a substantial compensatory award and a separate punitive award.

Issue

Does 42 U.S.C. § 1983 permit a jury to award compensatory damages based on its assessment of the value or importance of a constitutional right, rather than on actual injury caused by the deprivation? If not, was the erroneous instruction harmless where the general verdict did not reveal how damages were calculated?

Rule

In § 1983 cases, compensatory damages are governed by tort principles and must be designed to compensate for actual injury caused by the constitutional deprivation. Damages based on the abstract value or importance of constitutional rights are not a permissible element of compensatory damages, though nominal damages may vindicate rights without proof of actual injury and punitive damages may be separately available on the required showing.

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One of 10 multiple-choice questions for this case. Pick an answer to see why.

In Columbus, Ohio, a city librarian, Dana Ruiz, proves that she was transferred to a basement archive room in violation of her First Amendment rights. She kept the same salary and benefits and offers no evidence of emotional distress, reputational harm, or out-of-pocket loss.

If the jury wants to award Dana $75,000 in compensatory damages because free expression is vital to self-government, what is the most accurate result?

Explanation. The majority held that § 1983 compensatory damages follow tort principles and must compensate actual injury caused by the constitutional deprivation. A jury may not award damages based on the abstract value or importance of the right itself. Where no actual injury is proven, nominal damages may vindicate the right, and punitive damages may be separately available on the required showing, but substantial compensatory damages may not rest on the right's importance.