Supreme Court Rules in Favor of Student Punished for Religious Speech

8-1 ruling strikes blow against campus policies targeting religious expression

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March 8, 2021

The Supreme Court ruled Monday that taxpayer-funded colleges cannot punish students for expressing their religious beliefs.

Chike Uzuegbunam, an evangelical Christian student who graduated from Georgia Gwinnett College, a public college in Georgia, sued his alma mater after several incidents in 2016 during which he alleged the school violated his free speech rights by harassing him as he attempted to distribute religious materials on campus. The Court ruled 8-1 in favor of Uzuegbunam, finding that the school violated his constitutional rights and that he could still be awarded symbolic damages even though the school changed its policies and he graduated before the case was decided.

"It is undisputed that Uzuegbunam experienced a completed violation of his constitutional rights when respondents enforced their speech policies against him," Justice Clarence Thomas wrote in the majority opinion.

The Court weighed the significance of awarding Uzuegbunam and another Christian student a small payment, or "nominal damages," as recompense for the mistreatment they suffered from the university. Thomas wrote that the "nominal damages can redress Uzuegbunam’s injury even if he cannot or chooses not to quantify that harm in economic terms."

University police officers first approached Uzuegbunam as he distributed Christian literature on campus in 2016. The officers told him he could not distribute the literature because he was not in a university-designated "free speech zone." When Uzuegbunam moved to one of the zones, he was again told to stop because he was being disruptive. University officials allegedly threatened him with disciplinary action. Uzuegbunam, who was joined in the lawsuit by fellow Christian student Joseph Bradford, requested compensatory damages of one dollar to signify that the school had violated his rights. The school changed its speech policies after the incidents with Uzuegbunam, and he later graduated from the school, which caused lower courts to throw the case out for being effectively pointless.

Chief Justice John Roberts was the sole dissenter. Roberts argued that the case had little significance after the school changed its policies and the two students graduated, and that requiring the school to award symbolic damages would lessen the significance of symbolic damages.

"Petitioners Chike Uzuegbunam and Joseph Bradford want to challenge the constitutionality of speech restrictions at Georgia Gwinnett College," Roberts wrote. "There are just a few problems: Uzuegbunam and Bradford are no longer students at the college. The challenged restrictions no longer exist. And the petitioners have not alleged actual damages."

The case broke down ideological divides on the Court as both conservative and liberal justices signaled their sympathy for the plaintiff during oral arguments. Justice Elena Kagan said she believed that nominal damages are symbolically valuable and pointed to the case of musical artist Taylor Swift, who sued a DJ for allegedly groping her and asked for just one dollar in damages because "she wanted to prove a point," Kagan said.

Published under: Campus , Supreme Court