## Facts

- Two Arkansas public high school sophomores decided to add alcohol to punch at a school function attended by students and parents.
- A teacher later discovered the incident; the students admitted their conduct after initially believing the teacher would handle discipline.
- The principal learned of the incident and suspended the students for two weeks pending school board action.
- A school rule provided that use or possession of intoxicating beverages at school or school activities would be punished by suspension for the remainder of the semester.
- The school board voted to suspend the students for the balance of the semester and later declined to reconsider at a meeting attended by the students, their parents, and counsel.
- The students sued under 42 U.S.C. § 1983 seeking damages and injunctive and declaratory relief, alleging the suspensions violated due process.
- The district court directed verdicts for the school officials on damages based on immunity absent ill will; the court of appeals reversed on “substantive due process” grounds and ordered further proceedings.

## Issues

1. What immunity standard applies to local school board members and administrators sued for damages under 42 U.S.C. § 1983.
2. Whether § 1983 permits federal courts to relitigate evidentiary sufficiency and interpret school regulations in ordinary discipline disputes lacking a specific constitutional violation.
3. Whether the procedures used to suspend the students satisfied procedural due process (left unresolved below).

## Decision

- The Supreme Court vacated the court of appeals’ judgment and remanded.
- School officials are not absolutely immune from § 1983 damages; they have qualified good-faith immunity.
- Officials lose immunity if they knew or reasonably should have known their conduct would violate the student’s clearly established constitutional rights, or if they acted with malicious intent to cause a deprivation of rights or other injury.
- The Court rejected the court of appeals’ view that there was “no evidence” of a violation; the record supported discipline under a regulation properly read to forbid beverages containing alcohol.
- The Court held § 1983 is not a vehicle for routine federal correction of school officials’ discretionary decisions that do not amount to violations of specific constitutional guarantees.
- The Court remanded for consideration, in the first instance, of any unresolved procedural due process claim.

## Legal Principles

- School board members and school administrators sued for damages under § 1983 have qualified immunity, not absolute immunity.
- Qualified immunity has an objective and subjective component: liability may attach if officials (a) knew or should have known their acts would violate clearly established rights, or (b) acted with malicious intent to injure or deprive rights.
- Good-faith immunity bars damages only; it does not ordinarily bar equitable relief such as injunctions or declaratory judgments.
- Section 1983 does not create a general federal forum to reweigh evidence, re-interpret school regulations, or correct nonconstitutional errors of discretion in school disciplinary matters.

## Conclusion

The Court limited damages liability for public school officials by recognizing qualified immunity keyed to clearly established rights and malice, and it cautioned that § 1983 does not authorize routine federal second-guessing of school disciplinary judgments; the case was remanded to address any remaining procedural due process issues.


Wood v. Strickland, 420 U.S. 308 (1975)