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Uzuegbunam v. Preczewski
592 U.S. 279
SCOTUS
2021
Read the full case

Background

  • 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  • College officials rescinded the challenged policies; the parties agreed injunctive relief was moot, but disputed whether the nominal-damages claim preserved Article III jurisdiction.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)
Read the full case

Case Details

Case Name: Uzuegbunam v. Preczewski
Court Name: Supreme Court of the United States
Date Published: Mar 8, 2021
Citation: 592 U.S. 279
Docket Number: 19-968
Court Abbreviation: SCOTUS