## Facts

- Edward Stachura, a tenured seventh-grade life science teacher in a Michigan public school, used a board-approved textbook and showed materials some parents considered sexually explicit.
- After parental complaints about his teaching methods, the school district suspended him.
- Before reinstatement, Stachura sued the Memphis Community School District, its board members, administrators, and certain parents under 42 U.S.C. § 1983.
- He alleged deprivation of liberty and property without due process and violation of First Amendment academic freedom.
- He sought compensatory and punitive damages.
- The district court instructed the jury on standard compensatory and punitive damages and also allowed “additional” compensatory damages based on the “value” or “importance” of the constitutional rights violated.
- The jury found liability and awarded compensatory and punitive damages; the Sixth Circuit affirmed.

## Issues

1. Whether 42 U.S.C. § 1983 permits compensatory damages measured by the factfinder’s assessment of the abstract “value” or “importance” of a constitutional right.
2. Whether such “value-of-rights” damages can be treated as presumed damages in a § 1983 action.
3. Whether the inclusion of the improper instruction was harmless where the verdict did not separate injury-based damages from value-of-rights damages.

## Decision

- The Supreme Court reversed and remanded for a new trial limited to compensatory damages.
- Compensatory damages under § 1983 may cover proven economic loss and proven non-economic injury (e.g., humiliation, mental anguish, reputational harm) caused by the constitutional violation.
- The jury may not award compensatory damages based on the abstract worth of the constitutional right.
- The instructional error was not harmless because the compensatory award did not specify what portion reflected actual injury versus an impermissible valuation of rights.

## Legal Principles

- The basic purpose of § 1983 damages is compensation for injuries caused by the deprivation of constitutional rights.
- Section 1983 damages are generally measured by tort-damages principles, requiring a causal link between the violation and the plaintiff’s actual injury.
- “Value-of-rights” damages are not a permissible component of compensatory damages because they are untethered to actual injury and resemble punishment or deterrence rather than compensation.
- Presumed damages, where available, function as a substitute for proof of difficult-to-measure actual harm and may not be used to supplement a fully compensatory award.
- When a verdict does not segregate permissible injury-based damages from impermissible abstract-value damages, an improper instruction can require a new trial on compensatory damages.

## Conclusion

The Court held that § 1983 does not allow compensatory awards based on a jury’s assessment of the abstract importance of constitutional rights; compensation must be tied to actual, proven injury, requiring retrial when the verdict may have incorporated impermissible value-of-rights damages.


Memphis Cmty. Sch. Dist. v. Stachura, 477 U.S. 299 (1986)