Uzuegbunam v. Preczewski

In 2016, Chike Uzuegbunam, a student at Georgia Gwinnett College, distributed religious literature on campus but was stopped by campus police, who said college policy prohibited such distribution outside two designated free-speech zones. Uzuegbunam obtained a permit and spoke in a free-speech zone, but an officer again ordered him to stop after complaints, citing a policy against speech that disturbs the peace and/or comfort of person(s). Another student, Joseph Bradford, chose not to speak about religion because of these events. Both sued college officials under 42 U.S.C. § 1983, alleging First Amendment violations and seeking nominal damages and injunctive relief. The college revised its policies, then moved to dismiss the case as moot. The district court and the Eleventh Circuit held that the students lacked standing because they sought only nominal damages without compensatory damages. The Supreme Court reversed, holding that a request for nominal damages satisfies Article III's redressability requirement when a plaintiff's claim is based on a completed violation of a legal right.

In an 8-1 decision delivered by Justice Clarence Thomas on March 8, 2021, the Supreme Court reversed the judgment of the Eleventh Circuit and remanded the case. The Court held that a request for nominal damages satisfies the redressability element necessary for Article III standing where a plaintiff's claim is based on a completed violation of a legal right. Justice Kavanaugh filed a concurring opinion, and Chief Justice Roberts filed a dissenting opinion. On remand, the district court denied the defendants' attempt to deposit $1.00 to moot the case, and the case ultimately settled for nominal damages plus attorneys' fees exceeding $800,000.

Whether a request for nominal damages, without a claim for compensatory damages, satisfies the redressability element of Article III standing when a plaintiff's claim is based on a completed violation of a legal right, and whether a defendant's voluntary change of an challenged policy moots such a claim.

The decision eased access for plaintiffs to contest potential violations of First and Fourteenth Amendment speech and religious rights by allowing cases to proceed for nominal damages alone, even after a challenged policy is repealed. It makes it harder for local governments and public institutions to escape judicial review of unconstitutional policies simply by changing them once sued. The ruling has significant implications for free expression on college campuses, religious freedom, and government accountability, signaling that public officials cannot avoid liability for constitutional violations by voluntarily ceasing the challenged conduct.