Uzuegbunam v. Preczewski
The Facts
Chike Uzuegbunam, a Georgia Gwinnett College student, was stopped from distributing religious literature on campus by college administrators who cited campus speech zone restrictions and a prohibition on speech that 'disturbs the peace.' The college changed its speech policies after Uzuegbunam sued, which the Eleventh Circuit used to dismiss the case as moot. Uzuegbunam's only remaining claim was for nominal damages of one dollar. The question was whether that nominal claim alone was sufficient to maintain an Article III case or controversy.
The Application
Applying this rule, Uzuegbunam's nominal damages claim provided sufficient injury-in-fact to keep the case alive despite Georgia Gwinnett College's post-suit policy changes that would have otherwise mooted his injunctive and declaratory relief. Although the college changed its speech restrictions after Uzuegbunam filed suit, the Court held that his past legal injury, the constitutional violation that occurred when administrators stopped him from distributing religious literature, remained concrete and justiciable through his claim for one dollar in nominal damages. The vindication of that past right, even through symbolic monetary relief, satisfied Article III's requirement for an ongoing case or controversy throughout the litigation. This prevented the college from escaping review of its initial unconstitutional conduct simply by retreating from the challenged policy.
The Conclusion
The 2021 ruling ensures that defendants, including government defendants, cannot moot litigation by changing policies after being sued, as long as the plaintiff seeks nominal damages. The decision has broad implications for First Amendment and civil rights cases where government entities change their rules to avoid liability but have not remedied the past violation. It keeps the door open for plaintiffs seeking symbolic vindication of constitutional rights.
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Case Analysis
Overview
Uzuegbunam v. Preczewski (2021) held 8-1 that a claim for nominal damages, symbolic relief of one dollar, is sufficient to satisfy Article III's requirement that a plaintiff have a concrete, live stake in the controversy, even when a plaintiff's other claims for injunctive or declaratory relief become moot. The decision prevented lower courts from dismissing cases as moot simply because the defendant changed its policy after litigation began.
Facts
Chike Uzuegbunam, a Georgia Gwinnett College student, was stopped from distributing religious literature on campus by college administrators who cited campus speech zone restrictions and a prohibition on speech that 'disturbs the peace.' The college changed its speech policies after Uzuegbunam sued, which the Eleventh Circuit used to dismiss the case as moot. Uzuegbunam's only remaining claim was for nominal damages of one dollar. The question was whether that nominal claim alone was sufficient to maintain an Article III case or controversy.
Issue
Whether a plaintiff who seeks only nominal damages satisfies Article III's injury-in-fact requirement and the case-or-controversy requirement sufficient to keep a lawsuit alive, when all claims for injunctive and declaratory relief have become moot.
Rule
Article III, § 2 requires an ongoing, concrete, live controversy throughout litigation. Nominal damages are available at common law as a remedy when a plaintiff establishes a past legal injury. Under historical practice, courts could hear cases for nominal damages even when no other relief was available, because the vindication of the legal right itself is a concrete benefit.
Analysis
Applying this rule, Uzuegbunam's nominal damages claim provided sufficient injury-in-fact to keep the case alive despite Georgia Gwinnett College's post-suit policy changes that would have otherwise mooted his injunctive and declaratory relief. Although the college changed its speech restrictions after Uzuegbunam filed suit, the Court held that his past legal injury. The constitutional violation that occurred when administrators stopped him from distributing religious literature. Remained concrete and justiciable through his claim for one dollar in nominal damages. The vindication of that past right, even through symbolic monetary relief, satisfied Article III's requirement for an ongoing case or controversy throughout the litigation. This prevented the college from escaping review of its initial unconstitutional conduct simply by retreating from the challenged policy.
Conclusion
**The 2021 ruling ensures that defendants, including government defendants, cannot moot litigation by changing policies after being sued, as long as the plaintiff seeks nominal damages.** The decision has broad implications for First Amendment and civil rights cases where government entities change their rules to avoid liability but have not remedied the past violation. It keeps the door open for plaintiffs seeking symbolic vindication of constitutional rights.
Notes
OT2020. Added via SCOTUS bulk import 2026-05-14
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