Uzuegbunam v. Preczewski

"[For Article III standing requirements], [t]he plaintiff must have (1) suffered an injury in fact, (2) that is fairly traceable to the challenged conduct of the defendant, and (3) that is likely to be redressed by a favorable judicial decision." Spokeo, Inc. v. Robins, 136 S.Ct. 1540, 1547 (2016) (internal citation omitted).

Petitioner was a student at a public university (“University”), where officials informed him that he could not engage in religious speech except in “free speech expression areas” and with a permit. When Petitioner complied, his permit was revoked. Petitioner and another student sued the University seeking “injunctive relief and nominal damages,” at which point the University abandoned the policy. The District Court dismissed the matter, ruling that Petitioner lacked standing. The Eleventh Circuit Court of Appeals affirmed. On appeal to the Supreme Court, the University argued that the dispute was moot because of their policy change. Petitioner conceded that the injunctive relief was moot, but argued that their call for nominal damages remained reviewable. Article III requires that Plaintiffs (1) show an injury that is generally traceable to Defendants’ conduct and (2) seek a remedy that fairly rectifies the injury. U.S. Const. Art. III; see Spokeo, Inc. v. Robins, 136 S.Ct. 1540, 1547 (2016). Here, the Court found that nominal damages can rectify a past injury because American common law courts traditionally granted nominal damages for “any legal injury.” Therefore, the Court held that Petitioner had standing with regard to nominal damages. REVERSED and REMANDED.