Uzuegbunam v. Preczewski
592 U.S. 279
SCOTUS2021Background
- Uzuegbunam and Bradford, students at Georgia Gwinnett College, sought to share their Christian faith on campus; campus police twice ordered Uzuegbunam to stop and cited speech/distribution restrictions and complaints.
- College policy limited expressive activity to two tiny designated "free speech" zones and barred speech that "disturbs the peace and/or comfort of person(s)"; permits were required for zones.
- After enforcement events, Uzuegbunam and Bradford sued college officials under §1983 seeking injunctive relief and nominal damages for First Amendment violations.
- College officials rescinded the challenged policies; the parties agreed injunctive relief was moot, but disputed whether the nominal-damages claim preserved Article III jurisdiction.
- District court dismissed; Eleventh Circuit affirmed, holding nominal damages alone could not establish standing absent a claim for compensatory damages.
- Supreme Court reversed: held that a request for nominal damages satisfies redressability for Article III standing when the claim rests on a completed violation of a legal right; remanded (left Bradford’s individual standing for the lower court to decide).
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether nominal damages alone satisfy Article III redressability for a completed past constitutional violation | Nominal damages are concrete relief and can redress a completed legal injury, preserving jurisdiction | Nominal damages are merely symbolic; redress requires a claim for compensatory damages (or prospective relief) | Yes. Nominal damages satisfy redressability for completed legal-right violations (but plaintiff must still meet other standing elements) |
| Whether the case is moot as to both plaintiffs after policy repeal | Nominal damages keep the controversy live despite repeal | Policy change moots injunctive relief; nominal damages alone insufficient to prevent mootness | Uzuegbunam: standing preserved on nominal-damages theory; Bradford: Court did not decide—remanded for district court to determine if he suffered a completed injury |
Key Cases Cited
- Spokeo, Inc. v. Robins, 578 U.S. 330 (standing requires injury in fact, traceability, redressability)
- Church of Scientology of Cal. v. United States, 506 U.S. 9 (partial monetary relief can keep a case live)
- Farrar v. Hobby, 506 U.S. 103 (nominal damages constitute relief on the merits)
- Carey v. Piphus, 435 U.S. 247 (nominal damages appropriate for certain constitutional violations)
- Lujan v. Defenders of Wildlife, 504 U.S. 555 (plaintiff must maintain personal stake throughout litigation)
- Friends of the Earth, Inc. v. Laidlaw Environmental Services (TOC), Inc., 528 U.S. 167 (standing analyzed separately for each form of relief)
- Steel Co. v. Citizens for Better Environment, 523 U.S. 83 (courts cannot decide cases without jurisdiction; fees vs. redress distinction)
- Chafin v. Chafin, 568 U.S. 165 (mootness when no effectual relief can be granted)
- Memphis Community School Dist. v. Stachura, 477 U.S. 299 (remedies for §1983 claims derive from common law principles)
