UZUEGBUNAM v. PRECZEWSKI (2021)

United States Court of Appeals, Eleventh Circuit.2021-04-16No. No. 18-12676

Summary · law.co

Holding. The court reversed the district court's dismissal of the First Amended Complaint and remanded the case for further proceedings in light of the Supreme Court's holding that nominal damages awards alone can redress past injuries.

This panel initially upheld the dismissal of a constitutional challenge because prior circuit precedent held that nominal damages alone could not preserve a case that would otherwise be moot. The United States Supreme Court reversed that precedent, ruling that an award of nominal damages by itself is sufficient to redress a past injury and can maintain a case's viability. On remand, this court therefore reversed the district court's dismissal and returned the case for further proceedings consistent with the Supreme Court's new standard.

Summary generated by law.co from the public-domain opinion. The opinion text itself is public domain.

Key issues

Whether nominal damages alone can preserve a constitutional claim that would otherwise be moot
Mootness doctrine and Article III standing requirements
Sufficiency of remedies in First Amendment cases

Procedural posture

The case returned to the Eleventh Circuit following reversal by the United States Supreme Court.

Authorities cited

No cited authorities resolved to law.co cases yet.

Opinion · public domain

ON REMAND FROM THE SUPREME COURT OF THE UNITED STATES

When this case came to us initially, binding circuit precedent required that we conclude that Appellants’ nominal damages claims alone could not save their otherwise moot constitutional challenges. Uzuegbunam v. Preczewski, 781 F. Appx 824, 830-32 (11th Cir. 2019) (citing Flanigans Enters., Inc. of Ga. v. City of Sandy Springs, 868 F.3d 1248, 1263-71 (11th Cir. 2017) (en banc)). On March 8, 2021, the United States Supreme Court reversed this panels opinion, holding that “an award of nominal damages by itself can redress a past injury.” Uzuegbunam v. Preczewski, ––– U.S. ––––, 141 S. Ct. 792, 796, ––– L.Ed.2d –––– (2021). For the reasons stated in the Supreme Courts decision, we reverse the district courts dismissal of Appellants’ First Amended Complaint and remand for further proceedings consistent with the Supreme Courts decision. 1

REVERSED AND REMANDED.

FOOTNOTES

. The parties’ joint motion to extend all deadlines until thirty days after this Court issues its mandate is DENIED AS MOOT.

PER CURIAM: