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Copy of Wood V. Strickland
Transcript of Copy of Wood V. Strickland
February 18th, 1972
Mena Public High School (Polk County)
Virgina Crain, Peggy Strickland and Jo wall confessed to spiking the punch at an extracurricular function with 24-oz of flavored malt liquor.
Principal Duddy Waller suspended the three students for a week.
The same day, meeting in a closed session and without notice to the parents or students, the Mena School Board, led by superintendent S.L. Inlow, expelled the children for the remainer of the semester.
Punishment based on a school handbook policy requiring such an expulsion if intoxicating beverages were possessed or consumed at a school-sponsored event.
March 2nd, 1972-The students requested and received a full hearing before the school board. Proceeding vindicated the original decision of the school board and upheld the expulsion without modification.
They filed suit in the U.S. District Court for the Western District of Arkansas
Allegation- the students’ right to due process of law under the Fourteenth Amendment (equal protection and due process) had been denied. The students and their parents alleged that the students had not been allowed their basic right to a fundamentally fair hearing before expulsion.
The lawsuit Strickland v. Inlow was brought against Principal Waller, Superintendent Inlow, and the board members of the Mena Special School District, including John P. Wood.
Originally, the suit asked only for an order from the court to reinstate the students, but plaintiffs later added a claim for monetary damages as well.
The District Court's Decision
Suit tried by jury, with Federal District Judge Paul X presiding.
Jury could not reach unanimous decision.
Under the law that existed then, Judge Williams became the deciding agent.
He ruled that the school board and Inlow had not acted with any subjective malice and therefore immune to a suit for damages.
He dismissed the case, which was then appealed to the Court of Appeals for the Eight Circuit.
Court of Appeals
August 29th, 1973- In Strickland v. Inlow, a three-judge panel found that there existed legally sufficient evidence to require retrial on the issue of malice( board had no evidence to expel the girls.
The panel remanded the case to the District Court, but the school district asked for a rehearsing before the Eight Circuit en banc (by the entire bench). Th panel was affirmed on rehearsing.
The individual school board members sought and received review by the the U.S. Supreme Court. Neither the Superintendent Inlow, nor Principal Waller, nor the district as an entity appealed to the Supreme Court.
Hence the change of the name to Wood v. Strickland and the emphasis of the case on the potential liability of school board members individually
The Supreme Court's Decision
February 25th, 1975- Supreme Court ruled that school officials were cloaked with "qualified immunity" from lawsuit for money damages.
The standard set was that the members could be sued for damages ONLY IF he or she “reasonably knows” the action is in violation of constitutional rights or if malice intention was shown.
The Supreme Court further held that questions arising out of dischiplinary situations were best addressed by local officials rather than the courts.
This decision of was modified in Harlow V. Fitzgerald, that set forth that public officials would be personally liable for civil damages ONLY IF their conduct violated clearly established statutory or constitutional rights of which a reasonable person would have known;that defendants could assert immunity from liability because they acted in their official capacities, and that bareboned allegations of malice did not overcome that immunity
Implications for Educators
Laid down the principle that officials ordinarily should be immune in damages for reasonable actions taken in good faith as they go about their duties.
Thus, officials could do their job without fear of being sued for every action while preserving redress by lawsuit for damages for truly malicious and unwarranted actions by officials.
Teachers and administrators must be aware of constitutional rights and act in good faith of each student. Doing so, will help to prevent lawsuits and will allow the educators to concentrate on student achievement instead of being fearful of being sued.