Wood v. Strickland

The Court treated immunity as a question of statutory construction and considered the common-law immunities that survived § 1983's broad remedial language. Its prior cases recognized absolute immunity for legislators and judges, but only qualified immunity for executive officials whose jobs require discretionary judgments.

School-board members perform discretionary functions resembling both legislation and adjudication: they formulate school policy, assess alleged violations, and choose sanctions. They must often act promptly on information supplied by others, and exposure to damages for every good-faith error could intimidate officials, impair school administration, and deter qualified people from board service.

At the same time, absolute immunity would leave students without a damages remedy for intentional or otherwise unjustifiable constitutional deprivations. The common-law tradition and the purposes of § 1983 therefore supported an intermediate rule that protects reasonable good-faith decisionmaking while preserving accountability for culpable misconduct.

The Court rejected the District Court's rule that liability required proof of subjective malice or personal ill will. Good faith has both subjective and objective components: the official must sincerely believe the action is proper, but sincere ignorance or disregard of a student's settled constitutional rights cannot itself justify immunity.

School officials need not predict future developments in constitutional doctrine. But they are responsible for knowing their students' basic, clearly established constitutional rights. A damages award is proper only when the official acted with impermissible motivation or with such disregard of clearly established rights that the conduct cannot reasonably be called good faith.

This standard preserves room for reasonable mistakes made while exercising official discretion, but it does not permit officials to escape liability merely because they lacked personal hostility toward the student.

The Eighth Circuit treated “intoxicating beverage” as incorporating an Arkansas statutory definition requiring alcohol content above five percent by weight. The Supreme Court concluded that this was an erroneous construction of the school rule. Testimony showed that, when the rule was adopted, the board intended it to cover beer and alcoholic beverages generally, not only beverages meeting a technical statutory threshold.

The board's own earlier application of the rule, its findings that the students brought an alcoholic beverage onto school property, and the students' admissions all reinforced that interpretation. The students admitted purchasing malt liquor, mixing it into punch, and intending to spike the punch served at a school event.

Once the rule is properly understood to prohibit beverages containing alcohol, there was evidence of a violation. Federal courts may protect students' specific constitutional rights, but § 1983 is not a vehicle for federal courts to reweigh evidence in ordinary school disciplinary matters or to replace school administrators' reasonable interpretations of their own regulations with the court's preferred judgment.

The complaint alleged procedural as well as substantive due process violations. The Court of Appeals suggested that the first board meeting was procedurally deficient, while also suggesting that the later hearing attended by the students, parents, and counsel might have cured those deficiencies.

Because the District Court had not addressed the procedural claim and the Court of Appeals had not resolved it, the Supreme Court declined to decide the question itself. It vacated the judgment and remanded for further proceedings consistent with its immunity ruling and its rejection of the asserted substantive due process violation.