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Uzuegbunam v. Preczewski

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Supreme Court of the United States
Uzuegbunam v. Preczewski
Term: 2020
Important Dates
Argument: January 12, 2021
Decided: March 8, 2021
Outcome
Reversed and remanded
Vote
8-1
Majority
Clarence Thomas • Stephen Breyer • Samuel Alito • Sonia Sotomayor • Elena Kagan • Neil Gorsuch • Amy Coney Barrett
Concurring
Brett Kavanaugh
Dissenting
Chief Justice John G. Roberts

Uzuegbunam v. Preczewski is a case argued before the Supreme Court of the United States on January 12, 2021, during the court's October 2020-2021 term.

The court reversed the U.S. Court of Appeals for the 11th Circuit's judgment and remanded the case for further proceedings in an 8-1 decision, holding that a nominal damages request satisfies the necessary redressability element for Article III standing where a plaintiff's claim is based on a completed violation of a legal right. Justice Clarence Thomas delivered the majority opinion of the court. Justice Brett Kavanaugh filed a concurring opinion. Chief Justice John Roberts filed a dissenting opinion.[1] Click here for more information about the ruling.

HIGHLIGHTS
  • The case: In 2016, while a student at Georgia Gwinnett College, Chike Uzuegbunam was distributing religious literature on campus. Uzuegbunam was stopped by campus police and informed he was subject to disciplinary action if he continued to do so under the school's "Student Code of Conduct" and "Freedom of Expression Policy". Uzuegbunam and fellow student James Bradford filed suit against multiple school officials in district court, seeking declaratory judgment, injunctive relief, and nominal damages. While the case was pending, the school revised the school policies at issue and Uzuegbunam graduated from the school. The school officials moved for dismissal, claiming that the appellants' arguments were now moot because of the policy changes and because the appellants had failed to state a claim. The district court dismissed the case. On appeal, the 11th Circuit affirmed the district court's ruling. Uzuegbunam and Bradford petitioned the Supreme Court for review, citing a circuit split on the subject of mootness as it pertains to nominal damages claims.[2] Click here for more information about the case's background.
  • The issues: The case concerned mootness of nominal damages claims.
  • The questions presented: Whether a government's post-filing change of an unconstitutional policy moots nominal damages claims that vindicate the government's past, completed violation of a plaintiff's constitutional right.[2]
  • The outcome: The U.S. Supreme Court reversed the U.S. Court of Appeals for the 11th Circuit's judgment and remanded the case for further proceedings.


    • The case came on a writ of certiorari to the United States Court of Appeals for the 11th Circuit.[3] You can review the lower court's opinion here.[4]

    Timeline

    The following timeline details key events in this case:

    Background

    Procedural background

    Appellants Chike Uzuegbunam and Joseph Bradford were students at Georgia Gwinnett College (GGC). In July 2016, Uzuegbunam was distributing religious literature in an open outdoor area on the school's campus. He was stopped by a member of campus police who informed him that he could not distribute the literature at that location, according to the school's "Freedom of Expression Policy", which stated that in general, students could engage in such expression only in two designated speech zones on campus and that to access the speech zones, students had to reserve the spaces. Then, Uzuegbunam reserved one of the speech zones in order to distribute religious literature and to speak to students about his religious beliefs. Campus police asked Uzuegbunam to stop, informed him that he had reserved the speech zone for specific purposes that did not include open-air speaking, that they had received complaints regarding his speech, and that he was in violation of the school's "Student Code of Conduct" as his speech was considered a disturbance of the peace, or disorderly conduct and was subject to disciplinary action. Uzuegbunam opted to stop speaking and left the designated speech zone. James Bradford shared Uzuegbunam's religious beliefs and also wanted to speak publicly about those beliefs. Both students elected to self-censor.[2][4]

    The students (then appellants) filed suit against multiple Georgia Gwinnett College officials (the appellees) with the Northern District of Georgia under United States Code Title 42, Chapter 21, Subsection 1983, challenging the constitutionality of the two GGC policies in the student handbook, the "Freedom of Expression Policy" and the "Student Code of Conduct", seeking declaratory judgment that the two college policies at issue restricted expression and violated the appellants' First and Fourteenth Amendment rights, seeking injunctive relief against the enforcement of the two policies, nominal damages, and any other relief to which the appellants may be entitled.[4][6]

    The appellees moved to dismiss the first amended complaint for failure to state a claim. While that motion was pending, the school revised both policies. The revisions allowed students to speak anywhere on campus without requiring a permit except in specific limited circumstances and removed the challenged portion of its "Student Code of Conduct". The revised policies went into effect on February 28, 2017, and superseded the previous policies. Then, the appellees filed a motion to dismiss the first amended complaint as moot and a supplemental brief on the subject of mootness. While the case was pending in the district court, Uzuegbunam graduated from GGC. In response to the supplemental brief, the appellants argued that even if their claims for declaratory judgment and injunctive relief were moot, their first amended complaint included a request for compensatory damages and remained active. The appellants stated that if the court disagreed, the appellants should be allowed to amend and clarify their complaint's request for damages.[4]

    The Northern District of Georgia granted the appellees' motions to dismiss based on mootness and did not address whether the appellants' first amended complaint stated a claim on which relief could be granted. The court held that because Uzuegbunam graduated from GGC, his claims for declaratory judgment and injunctive relief were moot; it also held that GGC's revised policies in the student handbook mooted Bradford's claims and that the remaining claim for nominal damages did not support the overall case's standing. The court denied the appellants' request to amend their complaint to clarify their request for compensatory damages, stating that it was not procedurally proper to make that request in a response to a motion to dismiss. The court dismissed the case.[4]

    On appeal, the United States Court of Appeals for the 11th Circuit considered the dismissal of the case on the grounds of mootness de novo. On July 1, 2019, the 11th Circuit affirmed the Northern District of Georgia dismissal of the first amended complaint as moot in a per curiam decision.[4]

    On January 31, 2020, Chike Uzuegbunam and Joseph Bradford petitioned the U.S. Supreme Court for review. On July 9, 2020, the Supreme Court granted review.[3]

    Legal definitions

    42 U.S.C. § 1983

    The following subsection is from the United States Code, Title 42, Chapter 21, Section 1983:[6]

    “ Every person who, under color of any statute, ordinance, regulation, custom, or usage, of any State or Territory or the District of Columbia, subjects, or causes to be subjected, any citizen of the United States or other person within the jurisdiction thereof to the deprivation of any rights, privileges, or immunities secured by the Constitution and laws, shall be liable to the party injured in an action at law, suit in equity, or other proper proceeding for redress, except that in any action brought against a judicial officer for an act or omission taken in such officer's judicial capacity, injunctive relief shall not be granted unless a declaratory decree was violated or declaratory relief was unavailable. For the purposes of this section, any Act of Congress applicable exclusively to the District of Columbia shall be considered to be a statute of the District of Columbia.[7] ”
    —42 U.S.C. § 1983

    Questions presented

    The petitioner presented the following questions to the court:

    Questions presented:
    • Whether a government's post-filing change of an unconstitutional policy moots nominal damages claims that vindicate the government's past, completed violation of a plaintiff's constitutional right.[2]


    Oral argument

    Audio

    Audio of oral argument:[8]



    Transcript

    Transcript of oral argument:

    Outcome

    The court reversed the U.S. Court of Appeals for the 11th Circuit's judgment and remanded the case for further proceedings in an 8-1 decision, holding that a nominal damages request satisfies the necessary redressability element for Article III standing where a plaintiff's claim is based on a completed violation of a legal right. Justice Clarence Thomas delivered the majority opinion of the court. Justice Brett Kavanaugh filed a concurring opinion. Chief Justice John Roberts filed a dissenting opinion.[1]

    Opinion

    In his opinion, Justice Clarence Thomas wrote:[1]

    “ At all stages of litigation, a plaintiff must maintain a personal interest in the dispute. The doctrine of standing generally assesses whether that interest exists at the outset, while the doctrine of mootness considers whether it exists throughout the proceedings. To demonstrate standing, the plaintiff must not only establish an injury that is fairly traceable to the challenged conduct but must also seek a remedy that redresses that injury. And if in the course of litigation a court finds that it can no longer provide a plaintiff with any effectual relief, the case generally is moot. This case asks whether an award of nominal damages by itself can redress a past injury. We hold that it can.[7] ”
    —Justice Clarence Thomas

    Concurring opinion

    Justice Brett Kavanaugh filed a concurring opinion.[1]

    In his concurring opinion, Justice Kavanaugh wrote:

    “ I agree with the Court that, as a matter of history and precedent, a plaintiff's request for nominal damages can satisfy the redressability requirement for Article III standing and can keep an otherwise moot case alive. I write separately simply to note that I agree with THE CHIEF JUSTICE and the Solicitor General that a defendant should be able to accept the entry of a judgment for nominal damages against it and thereby end the litigation without a resolution of the merits. Post, at 11 (ROBERTS, C. J., dissenting); Brief for United States as Amicus Curiae 29–30[7] ”
    —Justice Brett Kavanaugh

    Dissenting opinion

    Chief Justice John Roberts filed a dissenting opinion.[1]

    In his dissent, Chief Justice Roberts wrote:[1]

    “ Petitioners Chike Uzuegbunam and Joseph Bradford want to challenge the constitutionality of speech restrictions at Georgia Gwinnett College. There are just a few problems: Uzuegbunam and Bradford are no longer students at the college. The challenged restrictions no longer exist. And the petitioners have not alleged actual damages. The case is therefore moot because a federal court cannot grant Uzuegbunam and Bradford “any effectual relief whatever.” Chafin v. Chafin, 568 U. S. 165, 172 (2013) (internal quotation marks omitted).


    The Court resists this conclusion, holding that the petitioners can keep pressing their claims because they have asked for "nominal damages." In the Court’s view, nominal damages can save a case from mootness because any amount of money—no matter how trivial—“can redress a past injury.” Ante, at 1. But an award of nominal damages does not alleviate the harms suffered by a plaintiff, and is not intended to. If nominal damages can preserve a live controversy, then federal courts will be required to give advisory opinions whenever a plaintiff tacks on a request for a dollar. Because I would place a higher value on Article III, I respectfully dissent.[7]

    		”
    —Chief Justice John Roberts

    Text of the opinion

    Read the full opinion here.

    October term 2020-2021

    See also: Supreme Court cases, October term 2020-2021

    The Supreme Court began hearing cases for the term on October 5, 2020. The court's yearly term begins on the first Monday in October and lasts until the first Monday in October the following year. The court generally releases the majority of its decisions in mid-June.[9]

    The court issued 67 opinions during its 2020-2021 term. Two cases were decided in one consolidated opinion. Ten cases were decided without argument. Click here for more information on the court's opinions.

    The court agreed to hear 62 cases during its 2020-2021 term. Of those, 12 were originally scheduled for the 2019-2020 term but were delayed due to the coronavirus pandemic. Five cases were removed from the argument calendar.


    See also

    External links

    Footnotes

    1. ↑ 1.0 1.1 1.2 1.3 1.4 1.5 U.S. Supreme Court, Uzuegbunam v. Preczewski, decided March 8, 2021
    2. ↑ 2.0 2.1 2.2 2.3 Supreme Court of the United States, "19-968 Uzuegbunam v. Preczewski: Questions presented," accessed July 9, 2020
    3. ↑ 3.0 3.1 SCOTUSblog, "Uzuegbunam v. Preczewski," accessed July 9, 2020
    4. ↑ 4.0 4.1 4.2 4.3 4.4 4.5 4.6 U.S. Court of Appeals for the 11th Circuit, Uzuegbunam v. Preczewski, decided July 1, 2019
    5. ↑ Cornell Law School Legal Information Institute, "Amended complaint," accessed July 9, 2020
    6. ↑ 6.0 6.1 Casetext, "42 U.S.C. § 1983," accessed July 13, 2020
    7. ↑ 7.0 7.1 7.2 7.3 Note: This text is quoted verbatim from the original source. Any inconsistencies are attributable to the original source.
    8. ↑ Supreme Court of the United States, "Oral Argument - Audio," accessed January 13, 2021
    9. ↑ SupremeCourt.gov, "A Brief Overview of the Supreme Court," accessed April 20, 2015
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