Introduction

Uzuegbunam v. Preczewski, 141 S. Ct. 792 (2021), marks a significant development in the interpretation of Article III standing, particularly concerning the role of nominal damages in maintaining a live controversy. This case revolves around former students of Georgia Gwinnett College who sought to exercise their religious freedoms on campus but were restricted by the college’s speech policies. The key issue addressed by the Supreme Court was whether a request for nominal damages alone can satisfy the redressability requirement necessary for Article III standing when the primary remedy, injunctive relief, has become moot.

Summary of the Judgment

The Supreme Court, through Justice Thomas, reversed the Eleventh Circuit's decision that denied standing to the petitioners, Uzuegbunam and Bradford, based solely on their claim for nominal damages after the college officials discontinued the challenged speech policies. The Court held that a request for nominal damages satisfies the redressability element of standing when a plaintiff has established a completed violation of a legal right. This decision underscores that nominal damages, even in the absence of compensatory damages, can uphold a plaintiff's standing to sue under Article III.

Analysis

Precedents Cited

The Court extensively referenced historical common law precedents to support its decision. Key among these were:

• Spokeo, Inc. v. Robins, 578 U.S. 330 (2016) – Established the three-pronged test for Article III standing: injury in fact, causation, and redressability.
• CHURCH OF SCIENTOLOGY OF CALIFORNIA v. UNITED STATES, 506 U.S. 9 (1992) – Highlighted the role of nominal damages as a form of redress.
• Hatch v. Lewis, 2 F. & F. 467 (N. P. 1861) – Demonstrated the historical awarding of nominal damages for legal violations without actual damages.
• Webb v. Portland Mfg. Co., 29 F. Cas. 506 (CC Me. 1838) – Emphasized that nominal damages suffice when a legal right has been violated.

Legal Reasoning

The Supreme Court’s legal reasoning centered on the historical availability of nominal damages as a remedy for legal rights violations, irrespective of actual or quantifiable damages. The Court argued that nominal damages serve as a salvo ensuring that plaintiffs have a means to vindicate their rights and are not deprived of relief due to the non-pecuniary nature of some injuries. By establishing that nominal damages meet the redressability requirement, the Court reinforced the principle that harm need not always be economically measurable to warrant judicial intervention.

Impact

This judgment has profound implications for the scope of Article III standing:

• Broadening Access to Courts: Plaintiffs can now maintain standing with nominal damages even when primary remedies are unavailable, potentially increasing the number of cases appellate courts review.
• Judicial Economy: By allowing nominal damages to preserve standing, courts can address legal rights violations without delving into the merits of the case, streamlining litigation.
• Protection of Non-Pecuniary Rights: Strengthens the protection of rights that do not easily translate into economic terms, such as free speech and religious expression.

Complex Concepts Simplified

Article III Standing

Article III of the U.S. Constitution restricts federal judicial power to "cases" and "controversies," ensuring that courts only decide actual disputes. To have standing, a plaintiff must demonstrate:

• Injury in Fact: A concrete and particularized harm.
• Causation: The injury must be traceable to the defendant’s actions.
• Redressability: The court must be able to provide a remedy that addresses the injury.

Nominal Damages

Nominal damages are small, symbolic sums awarded when a legal right has been violated, but no significant harm was proven. They serve to recognize the violation and uphold the plaintiff’s standing without addressing substantial compensatory damages.

Conclusion

The Supreme Court’s decision in Uzuegbunam v. Preczewski reaffirms the essential role of nominal damages in preserving a plaintiff’s standing under Article III. By recognizing that nominal damages can satisfy redressability, the Court ensures that violations of non-pecuniary rights are appropriately addressed, even in the absence of substantial economic harm. This judgment not only upholds the accessibility of federal courts for addressing constitutional rights violations but also reinforces the judiciary’s capacity to protect fundamental freedoms effectively.