Ruling May Curb Awards in Rights Cases

In a move that could limit damage awards by juries, the Supreme Court said Wednesday that the amount of money given to a person whose civil rights were violated should be based only on the actual injury suffered, not on the abstract value of the constitutional rights.

The justices unanimously overturned an award of $302,000 to a Michigan schoolteacher who had been briefly suspended with pay after a public uproar over his sex education class.

The lower courts had ruled, and the high court agreed, that the teacher’s rights were violated when he was removed from his job “based largely on inaccurate rumors about the allegedly sexually explicit nature of pictures and films” that were displayed in his seventh-grade classroom.

New Hearing Ordered

But the justices ordered a new hearing on damages because the jurors had been told to consider “the importance of the rights” to free speech and fair treatment and the “precise value you place” on those rights when they were setting the amount.

A judgment on the abstract value of a constitutional right is “an unwieldy tool” for making monetary awards and “therefore not a permissible element of compensatory damages in such cases,” Justice Lewis F. Powell Jr. wrote for the court.

The outcome was a victory for the Reagan Administration, which had urged the high court to halt loosely conceived jury awards that “grant needless windfalls to plaintiffs and impose unjustified and unforeseeable liability on government officials and agencies.”

However, a lawyer for the American Civil Liberties Union said the decision suggests that a government official could deny someone his constitutional rights with virtually no penalty.

Token Awards Feared

“Take the case of a speaker who shows up at a political rally and a policeman who stops him from speaking. After six years of litigation, the speaker could end up with a token $1 award because he couldn’t prove actual damages,” said George Kannar, an attorney for the ACLU, which backed the Michigan teacher.

The federal civil rights law includes provisions for damages in part to deter officials from violating those rights, “but a $1 fine won’t be much of a deterrent,” Kannar said.

The impact of the ruling is somewhat unclear, he added, because the justices appeared to disagree on whether juries could ever award damages in cases in which injuries were difficult to prove. Although Powell’s opinion says juries must look at “proof of actual injury,” Justice Thurgood Marshall, in a concurring statement joined by three others, said that “the violation of a constitutional right, in proper cases, may itself constitute a compensable injury.”

The case began in April, 1979, when students in Memphis, Mich., told their parents about viewing a school film on human sexuality and seeing photos of a teacher’s wife during childbirth. When the parents voiced complaints at a school board meeting and the session provoked a “total uproar,” the school officials voted to suspend the instructor.

The teacher, Edward Stachura, filed suit and showed at his trial that most of the pictures and the film strips had been provided by the school district. His lawyers pointed out also that the teacher had never been given a chance to defend himself after he was publicly branded “a sex maniac.”

Humiliation an Issue

The federal court ruled that the teacher’s civil rights had been violated by the sudden suspension and the adverse publicity it generated. After the judge told the jurors to consider both the humiliation suffered by Stachura and the “value” of the rights that were denied, the jury awarded him $275,000 in compensatory damages and $46,000 in punitive damages.

An appeals court upheld the ruling, despite reducing the total damage award to $302,000. The high court reviewed the case only on the question of compensatory damages (Memphis Community Schools vs. Stachura, 85-410).

The Supreme Court eases the way for news organizations to defend against libel suits. Page 24.