As stated by the Courta request for nominal compensation satisfies the redressability element required for Article III standing where a plaintiff’s claim is based on a completed breach of a legal right.
Facts of this Case
The suit was brough by former students at Georgia Gwinnett College who desired to exercise their religion by sharing their beliefs on campus while enrolled there. In 2016, Chike Uzuegbunam spoke with interested students and passed out religious literature on campus grounds. Uzuegbunam stopped after a campus police officer informed him that campus policy prohibited distributing written spiritual materials outside areas designated for this purpose. A school official later clarified to Uzuegbunam that he could speak about his religion or distribute substances only in two specified language regions on campus, and even then only after securing a license. But when Uzuegbunam got the required license and attempted to speak at a free speech zone, a campus police officer asked him to stop, now stating that individuals had complained about his speech.
Campus policy at the time prohibited utilizing the free speech zone to state anything that”disturbs the peace and/or relaxation of person(s).” The officer advised Uzuegbunam that his speech violated campus policy because it had led to complaints, and also the officer endangered Uzuegbunam with disciplinary action if he lasted. Uzuegbunam again complied with the order to stop speaking.
Another student who shares Uzuegbunam’s religion, Joseph Bradford, decided not to speak about religion because of these events. The two Uzuegbunam and Bradford sued certain college officials charged with enforcement of the faculty’s speech policies, arguing that these coverages violated the First Amendment. The students sought injunctive relief and minimal damages. The school officials ultimately opted to discontinue the challenged policies instead of to shield themand they sought dismissal on the ground that the policy shift left the students without standing to sue. The parties agreed that the policy shift rendered the students’ request for injunctive relief moot, however, contested whether the students had standing to keep the suit according to their remaining claim for nominal compensation. The Eleventh Circuit Court of Appeals held that while a request for nominal compensation can sometimes save a case from mootness, such as where a person pleads but fails to prove an amount of compensatory damages, the students’ request nominal damages could not by itself establish standing.
Supreme Court’s Conclusion
“This case asks if an award of nominal compensation by itself may redress a past injury. We hold that it could,” Justice Clarence composed on behalf of most.
As Justice Thomas clarified to establish Article III standing, the Constitution requires a plaintiff to spot the injury in fact that’s fairly traceable to the challenged conduct and to seek a remedy likely to redress this injury. To determine whether nominal compensation could remedy a previous accident, the Court looked to common law, noting that the rule at common law was that a party whose rights are vaccinated could always recover nominal damages without providing evidence of real damage. “Because nominal damages were offered at common law in analogous conditions, we conclude that a request for nominal compensation satisfies the redressability element of standing where a plaintiff’s claim is based on a completed breach of a lawful right,” Justice Thomas wrote.
While the Court acknowledged that”a single dollar often cannot offer complete redress,” it found that”to effectuate a partial remedy satisfies the redressability requirement” It further concluded that a contrary rule would result in”that the oddity of privileging small-dollar economic rights over important, but not readily quantifiable, nonpecuniary rights”
As Justice Thomas explained,”[n]ominal obligations are not a consolation prize for the plaintiff who pleads, but fails to prove compensatory damages. They are rather the compensation awarded by default before the plaintiff determines entitlement to some other type of compensation, including compensatory or statutory damages”
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