Uzuegbunam v. Preczewski

Supreme Court of the United States · 2021 · Federal Courts

592 U.S. 279 (2021)

Updated August 1, 2026

Federal Courtsnominal damagesmootnessArticle III standingredressabilitycompleted injuryconstitutional violationeffectual relief

Facts

Chike Uzuegbunam, a student at Georgia Gwinnett College, tried to share his faith and distribute religious literature on campus. College officials and campus police twice stopped him under campus speech policies, including a permit requirement limited to two designated speech areas and a rule forbidding speech that disturbed the peace or comfort of others; he stopped speaking after being threatened with discipline. Uzuegbunam and another student, Joseph Bradford, sued the officials enforcing those policies, seeking nominal damages and injunctive relief under the First Amendment. The college later abandoned the challenged policies, and the parties agreed the claim for injunctive relief was moot, leaving only nominal damages at issue.

Issue

Whether a plaintiff who alleges a completed constitutional violation and satisfies injury and traceability can satisfy Article III's redressability requirement by seeking only nominal damages after other requested relief has become moot.

Rule

A request for nominal damages satisfies the redressability element necessary for Article III standing where the plaintiff's claim is based on a completed violation of a legal right. Nominal damages provide effectual relief even if they do not fully compensate the injury.

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

Lena Ortiz, a resident of Phoenix, was removed from a city-council meeting after officials enforced a rule barring criticism of pending zoning proposals. She sued the city clerk under 42 U.S.C. § 1983 for injunctive relief and nominal damages. Six months later, Phoenix repealed the rule, and Lena concedes that injunctive relief is moot.

Assuming Lena adequately alleges a completed First Amendment violation and traceability, what is the strongest argument that her federal case remains live?

Explanation. The majority held that a request for nominal damages satisfies Article III redressability when the plaintiff's claim is based on a completed violation of a legal right. Nominal damages are not merely symbolic; they are relief on the merits and provide effectual, even if partial, redress. The Court rejected the idea that compensatory damages must also be pleaded or that attorney's fees can substitute for merits relief. (Derived from Uzuegbunam v. Preczewski (2021).)