## Facts

- Chike Uzuegbunam and Joseph Bradford were students at Georgia Gwinnett College (GGC), a public college, who sought to engage in religious speech and literature distribution on campus.
- In 2016, campus police stopped Uzuegbunam from distributing religious literature outside designated speech areas under GGC policy.
- A college official told Uzuegbunam he could speak or distribute materials only in two designated speech areas and only after obtaining a permit.
- After obtaining a permit and speaking in a designated area, campus police again stopped Uzuegbunam because complaints were made and a policy barred speech that “disturbs the peace and/or comfort of person(s),” with a threat of discipline if he continued.
- Uzuegbunam stopped speaking; Bradford refrained from engaging in similar speech due to these events.
- The students sued GGC officials in their official capacities seeking declaratory and injunctive relief and nominal damages for alleged First Amendment violations.
- After suit was filed, GGC revised its expression policy to allow speech broadly on campus without a permit (subject to limited exceptions) and removed the challenged “disturbs the peace and/or comfort” provision.

## Issues

1. Whether a request for nominal damages for a completed constitutional violation satisfies Article III’s redressability requirement when prospective relief becomes moot after the government changes the challenged policy.

## Decision

- The Supreme Court reversed the Eleventh Circuit and remanded (8–1).
- A claim for nominal damages can redress a completed violation of a legal right and therefore satisfies Article III redressability.
- The college’s policy change mooted requests for prospective relief but did not moot the claim for nominal damages addressing past injury.
- Dissent (Roberts, C.J.): nominal damages alone, after rescission of the challenged policy, do not provide practical redress and risk converting federal courts into forums for advisory constitutional rulings.

## Legal Principles

- Article III standing requires an injury in fact, traceability, and redressability; redressability is met when a court can grant relief that remedies the plaintiff’s injury.
- For a completed violation of a legal right, nominal damages are a traditional remedy that can redress the injury even without proof of compensatory harm.
- A live nominal-damages claim prevents mootness where the plaintiff seeks relief for past constitutional injury, even if later events eliminate the need for injunctive or declaratory relief.
- The holding is limited to completed violations; nominal damages are not available absent an established violation of a legal right.

## Conclusion

The Court held that plaintiffs alleging a completed constitutional violation may maintain federal jurisdiction through a request for nominal damages, because such an award supplies Article III redressability even when later policy changes moot forward-looking relief.


Uzuegbunam v. Preczewski, 592 U.S. 279 (2021)