Compensatory Damages as Full Redress:
Hammons v. University of Maryland Medical System Corp.
and the Limits of Appellate Standing for Nominal Damages

1. Introduction

Jesse Hammons— a transgender man whose scheduled hysterectomy was cancelled by the University of Maryland St. Joseph Medical Center—sued the hospital, its parent health-system, and an operating entity (collectively, “UMMS”) in federal district court. He asserted:

• Section 1557 of the Affordable Care Act (“ACA”) (statutory sex-discrimination claim);
• Equal Protection Clause claim; and
• Establishment Clause claim.

The district court dismissed the two constitutional counts but granted summary judgment on liability under § 1557. The parties then stipulated to $748.46 in compensatory damages ($874.63 including prejudgment interest), after which the court entered final judgment for Hammons.

Hammons appealed only the dismissal of his constitutional claims, seeking a retrospective declaratory judgment and nominal damages of $1. UMMS moved to dismiss, contending Hammons lacked Article III standing on appeal and that the matter was moot. The Fourth Circuit agreed, dismissing both Hammons’s appeal and UMMS’s conditional cross-appeal.

2. Summary of the Judgment

Writing for a unanimous panel, Judge Heytens held that Hammons failed the redressability prong of Article III standing. Because:

1. He had already obtained compensatory damages fully redressing the single injury—the surgery cancellation—and
2. A backward-looking declaratory judgment would afford no additional, concrete relief,

Hammons could not show a likelihood that any further remedy would flow from a favorable appellate decision. Nominal damages were foreclosed once compensatory damages were awarded, and a new theory (emotional-distress damages) raised for the first time at oral argument was waived.

3. Detailed Analysis

3.1 Precedents Cited

• Virginia House of Delegates v. Bethune-Hill, 587 U.S. 658 (2019) – reiterated that appellants, like initial plaintiffs, must establish Article III standing, including redressability.
• Uzuegbunam v. Preczewski, 592 U.S. 279 (2021) – clarified that nominal damages can independently satisfy redressability when no other damages are available, but are “actual” rather than “purely symbolic.” The Fourth Circuit applied Uzuegbunam to hold nominal damages are unavailable after compensatory damages are awarded.
• Comité de Apoyo a los Trabajadores Agrícolas v. U.S. Department of Labor, 995 F.2d 510 (4th Cir. 1993) – held that a purely retrospective declaratory judgment is not redress unless some additional concrete relief follows.
• Bender v. City of New York, 78 F.3d 787 (2d Cir. 1996) – stands for the “one injury, one recovery” rule; relied on to prevent dual awards of compensatory and nominal damages for the same harm.
• Schneider v. County of San Diego, 285 F.3d 784 (9th Cir. 2002) – distinguished by the panel because distinct constitutional injuries there justified separate awards.
• Cummings v. Premier Rehab Keller, PLLC, 596 U.S. 212 (2022) – bars emotional-distress damages under § 1557; cited to show the theory emerged too late in Hammons’s case.

3.2 Legal Reasoning

1. Standing on Appeal Mirrors Standing at Trial
   An appellant must show (a) injury, (b) traceability, and (c) redressability. The district-court judgment, not the original injury, is the focus. Hammons secured a money judgment; the only potential residual injuries were the dismissed constitutional claims themselves—non-justiciable absent additional relief.
2. Declaratory Relief Provides No Redress When Entirely Retrospective
   Fourth Circuit precedent treats backward-looking declarations as non-redressive unless they trigger further tangible benefits (e.g., injunction, damages, pre-emption of future enforcement). None were shown here.
3. Nominal versus Compensatory Damages
   Uzuegbunam recognized nominal damages as “real” but also emphasized they are awarded by default where no other damages are proven. Once Hammons recovered compensatory damages for the same underlying injury, the “default” evaporated.
4. One Injury, One Recovery Principle
   Relying on Bender, the court reiterated that a plaintiff may not obtain multiple monetary awards for a single harm under different legal theories.
5. Waiver of Untimely Theories
   The emotional-distress-damages argument surfaced only at oral argument, violating Fed. R. App. P. 28(a). The court refused to consider it, underscoring the necessity of preserving alternative bases for redress in the briefs.

3.3 Impact of the Decision

The ruling has significant forward-looking consequences:

• LGBTQ+ Health Litigation – Plaintiffs alleging both statutory and constitutional violations must strategize carefully: stipulating to compensatory damages under § 1557 can foreclose appellate review of constitutional theories if no additional relief remains.
• Nominal Damages Doctrine – The decision crystallizes a post-Uzuegbunam rule in the Fourth Circuit: nominal damages become unavailable once any other monetary damages fully compensate the injury. This curtails attempts to keep constitutional issues alive merely through a $1 claim.
• Appellate Practice – Counsel must plead all forms of uncompensated injury (e.g., emotional-distress, punitive damages, forward-looking injunctions) early and consistently to preserve standing.
• Health-care Providers & Religious Directives – While the substantive question of whether Catholic-affiliated hospitals may refuse gender-affirming care remains undecided at the Fourth Circuit level, UMMS’s litigation risk on constitutional grounds is temporarily contained due to the standing dismissal. Future plaintiffs will likely separate injuries (e.g., emotional distress, future access barriers) to avoid mootness.

4. Complex Concepts Simplified

• Article III Standing: The constitutional requirement that federal courts only decide live “cases or controversies.” It demands a concrete injury that a court can likely remedy.
• Redressability: One prong of standing; asks whether the court’s decision can give the plaintiff a tangible benefit.
• Nominal Damages: A token (often $1) awarded when a legal right is violated but no measurable economic harm can be shown. After Uzuegbunam, they suffice for standing only if no other damages are available.
• Compensatory Damages: Money intended to make a plaintiff whole for a proven, actual loss (medical bills, lost wages, etc.). Receipt of these damages usually precludes nominal damages for the same harm.
• Declaratory Judgment: A court declaration of the parties’ legal rights. A purely retrospective declaration—saying past conduct was illegal—does not ordinarily correct an injury or prevent future harm, so it lacks redressability without more.
• Stipulation: A binding agreement by the parties on a fact or amount (here, $748.46 in damages). Once adopted by the court, it becomes part of the judgment.
• Conditional Cross-Appeal: Filed by an appellee to protect its ability to challenge aspects of the lower-court ruling if, and only if, the appellate court reaches the merits. Dismissed as moot here because Hammons’s appeal was dismissed.

5. Conclusion

Hammons v. University of Maryland Medical System Corp. establishes a clear Fourth-Circuit precedent: when a plaintiff receives compensatory damages fully addressing the sole injury at issue, the plaintiff lacks appellate standing to pursue nominal damages or retrospective declaratory relief for that same injury. The decision tightens the doctrinal link between Uzuegbunam’s revitalization of nominal damages and the traditional “one injury, one recovery” rule, ensuring that nominal damages remain an alternative—not an add-on—to compensatory awards.

Future litigants must now thread a narrower needle: either forego compensatory damages, prove a distinct uncompensated injury (e.g., emotional distress), or craft forward-looking relief to preserve constitutional questions on appeal. The ruling, though unpublished and non-precedential, will undoubtedly guide district courts and practitioners throughout the Fourth Circuit confronting similar blends of statutory and constitutional health-care claims.