Memphis Community School District v. Stachura

477 U.S. 299 (1986).

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Nature of the Case

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Facts

Stachura (P), a tenured teacher, was suspended from teaching by Memphis (D) because of his teaching methods; allegedly showing sexually explicit pictures and films to a 7th-grade life science class. Parents complained to school officials about P’s teaching methods. At a school board meeting, a number of parents expressed the view that P should not be allowed to teach in the district. The day after the meeting P was suspended with pay. D later confirmed the suspension and notified that an administrative evaluation of his teaching methods was underway. No such evaluation was ever made. P was reinstated the next fall after filing this lawsuit. P sued; his constitutional rights were violated under the First Amendment right to academic freedom and that he was deprived of liberty and property without due process. The district court instructed the jury that compensatory and punitive damages could be awarded based on the value or importance of the rights that were violated. The jury awarded compensatory and punitive damages of $275,000 and $46,000. Judgment n.o.v. was entered as to one of the defendants, and the award was reduced to $266,750 and $36,000 respectively. The court of appeals affirmed. The Supreme Court granted certiorari.