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Supreme Court of the United States - 435 U.S. 247, 98 S. Ct. 1042, 55 L.Ed.2d 252, 435 U.S. 247, 55 L. Ed. 2d 252, 98 S. Ct. 1042, 1978 U.S. LEXIS 69, SCDB 1977-051
Tags: Civil Procedure, Remedies
tl;dr:
Denial of procedural due process without proof of actual injury is actionable only for nominal damages.Video Summary
Case Summary
In the 1978 case of Carey v. Piphus, two students, Piphus and Brisco, sued school officials (including Carey) for violating their procedural due process rights under the Fourteenth Amendment. They claimed they were suspended from public school without a hearing or chance to defend themselves. They sought different types of relief and damages through section 1983 in the federal district court.
The district court agreed that their rights were violated but didn't award damages as the students didn't prove actual injury from this violation. The court of appeals disagreed, saying they could be awarded damages for mental and emotional distress without proving actual injury. The Supreme Court, however, did not uphold this decision.
The Supreme Court used a two-part test to see if a jury trial was needed: the nature of the action and the remedy sought. They found that both parts leaned towards a jury trial, as it was a legal action for a constitutional rights violation and compensatory damages were a legal remedy. However, the Court also decided that damages couldn't be assumed from just the violation of procedural due process rights; proof of actual injury was needed.
This case is important as it shows how courts determine jurisdiction and choice of law in federal cases and how they balance enforcing federal laws while enforcing federal procedural law. It also demonstrates the use of civil procedure rules, like Rule 8(a) for pleading in civil actions.
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The legal case involves two students who were suspended from public schools without procedural due process. The Supreme Court held that in the absence of proof of actual injury, students are entitled to recover only nominal damages. The District Court found that the students were suspended without procedural due process, but declined to award damages due to lack of evidence of injury. The Court of Appeals reversed and remanded the case, holding that evidence submitted by respondents after judgment should have been considered to prove the pecuniary value of each day of school missed while suspended. The dispute is over whether plaintiffs must prove actual injury resulting from the deprivation of procedural due process before recovering substantial damages under § 1983. The respondents believe that damages under § 1983 should compensate for the deprivation of a constitutional right, while the petitioners argue that damages should compensate for injuries caused by the deprivation. Lower federal courts agree that damages under § 1983 should be based on the compensation principle.
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