Wood v. Strickland

Wood v. Strickland is the title of a U.S. Supreme Court decision that grew out of a local dispute over a teenage prank perpetrated by three high school students of the Mena Special School District. This case has attained an importance far beyond its origins, helping to define the constitutional rights of public school students and the parameters under which public officials may be sued for monetary damages in federal court.

On February 18, 1972, three students—Virginia Crain, Peggy Strickland, and Jo Wall—at Mena (Polk County) confessed to spiking the punch at an extracurricular function with twenty-four ounces of a flavored malt liquor beverage. 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 the children, the Mena School Board, led by then-superintendent S. L. Inlow, expelled the children for the balance of the semester based on a school handbook policy requiring such an expulsion if intoxicating beverages were possessed or consumed at a school-sponsored event.

The students requested and received a full hearing before the school board on March 2, 1972. This proceeding was deemed less than satisfactory by the students and their parents as it 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. The principal allegation of the suit was that the students’ right to due process of law under the Fourteenth Amendment 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.

Federal District Judge Paul X. Williams presided, as the matter was tried with a jury. However, the jury could not arrive at a unanimous decision. Under the law as it then existed, Judge Williams became the deciding agent. He ruled that the school board and Inlow had not acted with any subjective malice and were therefore immune to a suit for damages. He dismissed the case, which was then appealed to the Court of Appeals for the Eighth Circuit.

In its decision dated August 29, 1973, in Strickland v. Inlow a three-judge panel on the Eighth Circuit found that there existed legally sufficient evidence to require retrial on the issue of malice. The panel remanded the case to the District Court, but the school district asked for a rehearing before the Eighth Circuit en banc (that is, by the entire bench). The panel was affirmed on rehearing. The individual school board members sought and received review by the U.S. Supreme Court. Neither Superintendent Inlow, nor Principal Waller, nor the district as an entity appealed to the Supreme Court, hence the change of name to Wood v. Strickland and the emphasis of the case on the potential liability of school board members individually.

On February 25, 1975, the Supreme Court ruled that school officials were cloaked with “qualified immunity” from a lawsuit for money damages. The standard set was that the members could be sued for damages only if their actions were purposeful and violated well-settled principles of law regarding the rights of individuals affected. The test was thus to be objective and not subjective as to the issues of the case. In the final analysis, the Supreme Court further held that questions arising out of disciplinary situations were best addressed by local officials rather than the courts. This principle has been applied to numerous other constitutional contexts and, along with a handful of other federal cases during the administration of President Richard Nixon, Wood v. Strickland 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 egregious and unwarranted actions by officials.

For additional information:
Lee, David W. 2005 Handbook of Section 1983 Litigation. New York: Aspen Publishers, 2005.

Ross, Bobby R. “School Board Members’ Immunity from §1983 Suits—Wood v. Strickland.” Arkansas Law Review 29 (Winter 1976): 554–551.

Strickland v. Inlow, decision, USDC WD Ark. Federal Supplement, Vol. 348. St. Paul, MN: West Publishing, 1972.

Strickland v. Inlow, decision, United States 8^th Circuit Court of Appeals. Federal Reporter Second, Vol. 485. St. Paul, MN: West Publishing, 1973.

Wood v. Strickland, decision, United States Supreme Court. United States Reports, Vol. 420. United States Supreme Court Reporter of Decisions. Washington DC: Government Printing Office, 1975.

David Bowden
Little Rock, Arkansas