Wood v. Strickland

Incident Summary & Facts

Peggy Strickland and Virginia Crain, both 16-year-old tenth graders at Mena Public High School in Arkansas, and a third girl “spiked” the punch for a meeting of an extracurricular group attended by students and parents. Because their county was “dry,” they drove into Oklahoma, bought two 12-ounce bottles of “Right Time” malt liquor, and mixed it with soft drinks. The punch was served “without apparent effect.” Ten days later, after questioning by their teacher, the girls admitted their role to the principal, who suspended them for up to two weeks pending school board action.

At a board meeting that night, which neither the girls nor their parents attended, the teacher and principal first recommended leniency. They withdrew those recommendations after a report that the third girl had been in a fight at a basketball game that evening. The board expelled the girls for the rest of the semester, about three months. A second meeting, attended by the girls, their parents, and counsel, left the expulsion in place. The malt liquor was later shown to contain no more than 3.2% alcohol by weight, and the punch about 0.91%.

The students sued board members and others under 42 U.S.C. § 1983 for due process violations, seeking damages and equitable relief. After a mistrial, the district court directed verdicts for the defendants, finding them immune absent proof of malice. The Eighth Circuit reversed, finding a substantive due process violation and applying an objective good-faith standard. The case did not involve a use-of-force encounter; it concerns official immunity from § 1983 damages.

Core Legal Issue

What standard of immunity from § 1983 damages applies to school board members, and whether the Court of Appeals properly found a substantive due process violation where it concluded there was no evidence that the students possessed an “intoxicating” beverage.

The Holding

School board members have a qualified good-faith immunity, not an absolute one. They lose it if they “knew or reasonably should have known” their action would violate a student’s constitutional rights, or acted “with the malicious intention to cause a deprivation of constitutional rights or other injury.” The Court of Appeals’ substantive due process ruling rested on a misreading of the school regulation, so its judgment was vacated and the case remanded, including for consideration of the procedural due process claim.

The Court’s Analysis:

• Building on Tenney, Pierson v. Ray, and Scheuer v. Rhodes, the Court read § 1983 against common-law tradition and public policy. Some immunity is needed so that officials do not act with “undue timidity,” while absolute immunity would leave students with no remedy for “intentional or otherwise inexcusable deprivations.”
• The standard has both subjective and objective elements. The official must act “sincerely and with a belief that he is doing right.” But an official’s “ignorance or disregard of settled, indisputable law” can no more justify a violation than “actual malice.” Officials are not “charged with predicting the future course of constitutional law.” Damages are appropriate only where the official disregarded “clearly established constitutional rights.”
• On the merits, the Court of Appeals erred in tying “intoxicating beverage” to the Arkansas statutory definition. The board intended the rule to cover alcoholic beverages such as beer, and the girls’ admissions supplied evidence of a violation. Section 1983 is not a vehicle to “relitigate in federal court evidentiary questions arising in school disciplinary proceedings or the proper construction of school regulations.”
• The procedural due process claim, which neither lower court resolved, was left for the Court of Appeals on remand.
• Partial dissent (Powell, J., joined by Burger, C.J., Blackmun and Rehnquist, JJ.): The majority’s “settled, indisputable law” test imposes a harsher standard on lay school officials than Scheuer applied even to a governor. The proper test is whether the officer “acted reasonably and in good faith” under the circumstances as they appeared. He observed that “[n]ot even police officers were held liable for ignorance of ‘settled, indisputable law.’”