Barcik v. Kubiaczyk

In Barcik v. Kubiaczyk, 321 Ore. 174, 895 P.2d 765 (1995), several high school seniors challenged school district regulations that authorized school administrators to review and censor student publications and to discipline students who distributed or published material in violation of the regulations. Despite the fact that the seniors had graduated at the time of its ruling, the trial court entered a judgment declaring that the students' rights to free speech had been violated. The Supreme Court reversed, concluding that, under Oregon law, the plaintiffs' claims for declaratory and injunctive relief became moot upon their graduation from high school. The court reasoned: "On the date of the circuit court's judgment, no Senior plaintiff had any right or claim that would be affected by a declaratory judgment. Senior plaintiffs suffered no continuing harm from the alleged past deprivation of their Article I, section 8, rights. Similarly, because no Senior plaintiff had any right that was being violated at the time the circuit court entered judgment, there was nothing for the circuit court to enjoin with regard to Senior plaintiffs. Senior plaintiffs' claims were moot." Barcik, 321 Ore. at 187. The Oregon Supreme Court held that, "an Oregon court cannot apply state standards of mootness and justiciability to a section 1983 claim brought in state court if application of those standards would preclude a plaintiff's federal claim, but application of federal standards would not." Barcik, 321 Ore. at 185. Relying on its own prior case law and United States Supreme Court caselaw, the court reasoned that: "if state standards of mootness and justiciability are applied to plaintiffs' section 1983 claims raised in state court, plaintiffs will be prevented from securing injunctive relief and their 'uniquely federal remedy' in state court. Application of state standards of mootness and justiciability also would limit the rights that a plaintiff has in a federal claim, simply because that claim is brought in state court." Id.