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
- What immunity standard applies to local school board members and administrators sued for damages under 42 U.S.C. § 1983.
- Whether § 1983 permits federal courts to relitigate evidentiary sufficiency and interpret school regulations in ordinary discipline disputes lacking a specific constitutional violation.
- 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.