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Compensatory Damages Not Allowed for Value of Violated Rights
The U.S. Supreme Court reversed the Sixth Circuit's affirmation of a
district court's award of compensatory damages. A Michigan public school
teacher brought suit against a school district under 42 U.S.C. §1983 upon
suspension for his teaching methods. A jury awarded $275,000 in
compensatory damages on the district court's instructions that additional
compensatory damages could be awarded according to the value or importance
placed on the violated constitutional rights. The Supreme Court held that
such abstract value may not form the basis for §1983 damages, and found no
merit in the argument that the challenged jury instructions authorized
presumed damages. Presumed damages are a substitute for ordinary
compensatory damages, not a supplement. See: Stachura v. Truszkowski, 763
F.2d 211 (6th Cir. 1985) and Memphis Community School District v. Stachura,
477 U.S. 299, 306, 106 S.Ct. 2537, 2542, 91 L.Ed.2d 249 (1986).
district court's award of compensatory damages. A Michigan public school
teacher brought suit against a school district under 42 U.S.C. §1983 upon
suspension for his teaching methods. A jury awarded $275,000 in
compensatory damages on the district court's instructions that additional
compensatory damages could be awarded according to the value or importance
placed on the violated constitutional rights. The Supreme Court held that
such abstract value may not form the basis for §1983 damages, and found no
merit in the argument that the challenged jury instructions authorized
presumed damages. Presumed damages are a substitute for ordinary
compensatory damages, not a supplement. See: Stachura v. Truszkowski, 763
F.2d 211 (6th Cir. 1985) and Memphis Community School District v. Stachura,
477 U.S. 299, 306, 106 S.Ct. 2537, 2542, 91 L.Ed.2d 249 (1986).
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Related legal case
Stachura v. Truszkowski
| Year | 1986 |
|---|---|
| Cite | 763 F.2d 211 (6th Cir. 1985) |
| Level | Supreme Court |
| Attorney Fees | 0 |
| Damages | 0 |
| Injunction Status | N/A |
Stachura v. Truszkowski, 763 F.2d 211 (6th Cir. 06/03/1985)
[1] UNITED STATES COURT OF APPEALS FOR THE SIXTH CIRCUIT
[2] Nos. 82-1575, 83-1344, 83-1345
[3] 763 F.2d 211
[4] June 3, 1985
[5] EDWARD J. STACHURA, PLAINTIFF-APPELLANT, (83-1344)
v.
DELORES TRUSZKOWSKI, DEFENDANT-APPELLEE EDWARD J. STACHURA, ET AL, PLAINTIFFS-APPELLEES, (82-1575), CROSS APPELLEES, (83-1345) V. MEMPHIS COMMUNITY SCHOOL DISTRICT, A PUBLIC BODY, BOARD OF EDUCATION OF THE MEMPHIS COMMUNITY SCHOOLS, HERBERT KUBISH, GENEVIEVE WALTERS, MARGARET GUOIN, TIMOTHY KELLEY, LAWRENCE DELEKTA, ERNEST BEAUDRIE, BEATRICE DOLAN AND DONALD D. RUSSEL, DEFENDANTS-APPELLANTS, (82-1575), CROSS APPELLANTS, (83-1345)
[6] On Appeal from the United States District Court for the Eastern District of Michigan.
[7] Patrick J. Berardo, Thrun, Maatsch and Nordberg, 501 South Capitol, Suite 500, Lansing, Michigan 48933, for Appellant, Patrick B. Mooney, argued.
[8] Erwin B. Ellmann, Marshall W. Anstandig, 3000 Town Center, Suite 1800, Southfield, Michigan 48075, for Appellee, Jeffrey A. Heldt, argued.
[9] Erwin B. Ellman, Jeffrey A. Heldt, argued, Levin, Levin, Garvett and Dill, 3000 Town Center, Suite 1800, Southfield, Michigan 48075, for Appellant, Cross Appellee.
[10] Patrick B. Mooney, argued, Thrun, Maatsch and Nordberg, Suite 500, 501 South Capitol Avenue, Lansing, Michigan 48933, Patrick J. Berardo, for Appellee, Cross Appellant.
[11] Author: Edwards
[12] Edwards*fn* and Martin, Circuit Judges; and Peck, Senior Circuit Judge.
[13] EDWARDS, Circuit Judge
[14] Plaintiffs Edward Stachura and James MacDonald brought this action under 42 U.S.C. § 1983. They alleged violations of plaintiff Edward Stachura's rights under the Fourteenth Amendment guarantees of liberty and property against the Memphis Community School Board, the Memphis Community School District, individual members of the School Board, Donald Russell, School Superintendent, during the period involved, Robert Phillips, school superintendent who succeeded Donald Russell, Charles Becker, Principal of the Memphis Middle School and two private citizens, Delores Truszkowski and Marilyn Moore. As to all of the individuals, plaintiffs alleged a conspiracy to violate their First Amendment rights as a teacher in the instance of Stachura and as a student in the instance of MacDonald. After a lengthy jury trial, the jury found in favor of plaintiff Stachura against most of the defendants (including Truszkowski) and against plaintiff MacDonald in all of his claims.
[15] Two motions for judgment n.o.v. were filed. Truszkowski filed one such motion relying on the First Amendment. The School Board, its members and the named school officials also filed a motion for judgment n.o.v.
[16] Judge Harvey granted judgment notwithstanding the verdict to defendant Truszkowski and plaintiff Stachura appeals. The jury had found $18,250 damages, $10,000 of which were punitive, against Truszkowski. Judge Harvey set these judgments aside. He held that Truszkowski was entitled to immunity on the basis of the right to petition contained in the First Amendment to the Constitution of the United States.
[17] As to the second appeal named above, Stachura v. Memphis Community School Board, et al., the Board and other named defendants-appellants, appeal from a jury award of $321,000 punitive and compensatory damages.
[18] Judge Harvey wrote a lengthy opinion dealing with the two appeals which have been taken in this case. We have reviewed that opinion and adopt and rely upon it. Additionally, however, we make the following comments about the two appeals.
[19] Stachura v. Truszkowski
[20] Appellee Truszkowski was responsible for starting the sequence of events which transpired in these two cases. She organized and transmitted complaints to the School Board concerning Stachura's teaching of a Life Science class alleging improper teaching methods. Various other parents in the community joined her subsequently in vehement and continuing protests, based on unfounded rumors, leading directly to Stachura's removal. Although Truszkowski's role was pivotal in initiating these protests, it was made to the public body having charge of the educational system in the community concerned. As such, it was protected, as the District Judge held, by the right to petition encompassed in the First Amendment to the Constitution of the United States, In applicable part the First Amendment says: "Congress shall make no law . . . abridging . . . the right of the people . . . to petition the government for a redress of grievances." While Ms. Truszkowski's role in these events is not a pretty one, we agree with the District Judge that it was a petition addressed to the proper authority and as a consequence, her actions were immunized from this suit by her First Amendments rights. Gorman Towers v. Bogoslavsky,626 F.2d 607, 614-15 (8th Cir. 1980) ; see California Motor Transport Co. v. Trucking Unlimited, 404 U.S. 508, 30 L. Ed. 2d 642, 92 S. Ct. 609 (1972) ; Eastern Railroad Presidents Conference v. Noerr Motor Freight, 365 U.S. 127, 5 L. Ed. 2d 464, 81 S. Ct. 523 (1961).
[21] For these reasons, we affirm the judgment of the District Court in entering judgment notwithstanding the verdict thus setting aside the jury's verdict against defendant Truszkowski.
[22] Stachura v. Memphis Community School District, et al.
[23] As to Stachura's suit against the School Board and other defendants, we again find ourselves in agreement with the District Judge. The record in this case, when the motion for judgment notwithstanding the verdict is considered, must be viewed in the light most favorable to the party against whom the motion is made while giving that party the advantage of any reasonable inference the evidence can justify. The District Judge rejected defendants' position on plaintiff Stachura's First Amendment claim, his property interest claim, his liberty interest claim, the defense of good faith immunity and the question of punitive damages. As the District Judge pointed out, the text he used in teaching the Life Science class was approved by the School Board itself. The Life Science text included the following outline of Chapter 12 entitled "Reproduction."
[24] CHAPTER 12 REPRODUCTION 205
[25] The Nature of the Process 205
[26] Cells can reproduce themselves. Cells can grow.
[27] Cells can specialize. Lesson Review.
[28] Asexual and Sexual Reproduction 209
[29] Asexual reproduction is simple and fast. Sexual reproduction is more complicated. Sexual reproduction is the more common method. Genes enter the picture. Sexual reproduction is a safety mechanism.
[30] Lesson Review
[31] Laboratory Activity
[32] How Fast Does Yeast Reproduce Asexually ? 212
[33] The Human Reproductive Process 215
[1] UNITED STATES COURT OF APPEALS FOR THE SIXTH CIRCUIT
[2] Nos. 82-1575, 83-1344, 83-1345
[3] 763 F.2d 211
[4] June 3, 1985
[5] EDWARD J. STACHURA, PLAINTIFF-APPELLANT, (83-1344)
v.
DELORES TRUSZKOWSKI, DEFENDANT-APPELLEE EDWARD J. STACHURA, ET AL, PLAINTIFFS-APPELLEES, (82-1575), CROSS APPELLEES, (83-1345) V. MEMPHIS COMMUNITY SCHOOL DISTRICT, A PUBLIC BODY, BOARD OF EDUCATION OF THE MEMPHIS COMMUNITY SCHOOLS, HERBERT KUBISH, GENEVIEVE WALTERS, MARGARET GUOIN, TIMOTHY KELLEY, LAWRENCE DELEKTA, ERNEST BEAUDRIE, BEATRICE DOLAN AND DONALD D. RUSSEL, DEFENDANTS-APPELLANTS, (82-1575), CROSS APPELLANTS, (83-1345)
[6] On Appeal from the United States District Court for the Eastern District of Michigan.
[7] Patrick J. Berardo, Thrun, Maatsch and Nordberg, 501 South Capitol, Suite 500, Lansing, Michigan 48933, for Appellant, Patrick B. Mooney, argued.
[8] Erwin B. Ellmann, Marshall W. Anstandig, 3000 Town Center, Suite 1800, Southfield, Michigan 48075, for Appellee, Jeffrey A. Heldt, argued.
[9] Erwin B. Ellman, Jeffrey A. Heldt, argued, Levin, Levin, Garvett and Dill, 3000 Town Center, Suite 1800, Southfield, Michigan 48075, for Appellant, Cross Appellee.
[10] Patrick B. Mooney, argued, Thrun, Maatsch and Nordberg, Suite 500, 501 South Capitol Avenue, Lansing, Michigan 48933, Patrick J. Berardo, for Appellee, Cross Appellant.
[11] Author: Edwards
[12] Edwards*fn* and Martin, Circuit Judges; and Peck, Senior Circuit Judge.
[13] EDWARDS, Circuit Judge
[14] Plaintiffs Edward Stachura and James MacDonald brought this action under 42 U.S.C. § 1983. They alleged violations of plaintiff Edward Stachura's rights under the Fourteenth Amendment guarantees of liberty and property against the Memphis Community School Board, the Memphis Community School District, individual members of the School Board, Donald Russell, School Superintendent, during the period involved, Robert Phillips, school superintendent who succeeded Donald Russell, Charles Becker, Principal of the Memphis Middle School and two private citizens, Delores Truszkowski and Marilyn Moore. As to all of the individuals, plaintiffs alleged a conspiracy to violate their First Amendment rights as a teacher in the instance of Stachura and as a student in the instance of MacDonald. After a lengthy jury trial, the jury found in favor of plaintiff Stachura against most of the defendants (including Truszkowski) and against plaintiff MacDonald in all of his claims.
[15] Two motions for judgment n.o.v. were filed. Truszkowski filed one such motion relying on the First Amendment. The School Board, its members and the named school officials also filed a motion for judgment n.o.v.
[16] Judge Harvey granted judgment notwithstanding the verdict to defendant Truszkowski and plaintiff Stachura appeals. The jury had found $18,250 damages, $10,000 of which were punitive, against Truszkowski. Judge Harvey set these judgments aside. He held that Truszkowski was entitled to immunity on the basis of the right to petition contained in the First Amendment to the Constitution of the United States.
[17] As to the second appeal named above, Stachura v. Memphis Community School Board, et al., the Board and other named defendants-appellants, appeal from a jury award of $321,000 punitive and compensatory damages.
[18] Judge Harvey wrote a lengthy opinion dealing with the two appeals which have been taken in this case. We have reviewed that opinion and adopt and rely upon it. Additionally, however, we make the following comments about the two appeals.
[19] Stachura v. Truszkowski
[20] Appellee Truszkowski was responsible for starting the sequence of events which transpired in these two cases. She organized and transmitted complaints to the School Board concerning Stachura's teaching of a Life Science class alleging improper teaching methods. Various other parents in the community joined her subsequently in vehement and continuing protests, based on unfounded rumors, leading directly to Stachura's removal. Although Truszkowski's role was pivotal in initiating these protests, it was made to the public body having charge of the educational system in the community concerned. As such, it was protected, as the District Judge held, by the right to petition encompassed in the First Amendment to the Constitution of the United States, In applicable part the First Amendment says: "Congress shall make no law . . . abridging . . . the right of the people . . . to petition the government for a redress of grievances." While Ms. Truszkowski's role in these events is not a pretty one, we agree with the District Judge that it was a petition addressed to the proper authority and as a consequence, her actions were immunized from this suit by her First Amendments rights. Gorman Towers v. Bogoslavsky,626 F.2d 607, 614-15 (8th Cir. 1980) ; see California Motor Transport Co. v. Trucking Unlimited, 404 U.S. 508, 30 L. Ed. 2d 642, 92 S. Ct. 609 (1972) ; Eastern Railroad Presidents Conference v. Noerr Motor Freight, 365 U.S. 127, 5 L. Ed. 2d 464, 81 S. Ct. 523 (1961).
[21] For these reasons, we affirm the judgment of the District Court in entering judgment notwithstanding the verdict thus setting aside the jury's verdict against defendant Truszkowski.
[22] Stachura v. Memphis Community School District, et al.
[23] As to Stachura's suit against the School Board and other defendants, we again find ourselves in agreement with the District Judge. The record in this case, when the motion for judgment notwithstanding the verdict is considered, must be viewed in the light most favorable to the party against whom the motion is made while giving that party the advantage of any reasonable inference the evidence can justify. The District Judge rejected defendants' position on plaintiff Stachura's First Amendment claim, his property interest claim, his liberty interest claim, the defense of good faith immunity and the question of punitive damages. As the District Judge pointed out, the text he used in teaching the Life Science class was approved by the School Board itself. The Life Science text included the following outline of Chapter 12 entitled "Reproduction."
[24] CHAPTER 12 REPRODUCTION 205
[25] The Nature of the Process 205
[26] Cells can reproduce themselves. Cells can grow.
[27] Cells can specialize. Lesson Review.
[28] Asexual and Sexual Reproduction 209
[29] Asexual reproduction is simple and fast. Sexual reproduction is more complicated. Sexual reproduction is the more common method. Genes enter the picture. Sexual reproduction is a safety mechanism.
[30] Lesson Review
[31] Laboratory Activity
[32] How Fast Does Yeast Reproduce Asexually ? 212
[33] The Human Reproductive Process 215