District Court also ruled, however, that though parent/defendant Delores Truszkowski's allegations to the nature of Stachura's teaching methods were unfounded, her First Amendment rights were protected as she was petitioning the government. Both decisions were revisited in the Sixth Circuit Court of Appeals (Stachura v. Truszkowski, 1985).
Judge Edwards of the Sixth Circuit delivered the opinion which affirmed the District Court's ruling in its entirety. In his justifications, he noted "Stachura suffered the embarrassment of extensive publicity in the local media which repeated the allegations against him" (Stachura v. Truszkowski, 1985) and the Court agreed the actions taken against Stachura caused him significant professional harm.
Constitutionality aside, the case did reach the United States Supreme Court, which granted certiorari limited to issues of damages Stachura received. Justice Powell ordered the case remanded only to revisit a categorical redundancy in Stachura's awarded damages. The Court otherwise maintained the Sixth Circuit's affirmation of Stachura's rights to academic freedom within the bounds of curriculum, as well as his due process rights concerning his property interest (Memphis Community School District v. Stachura, 1986).
Throughout recent history academic freedom has been tested in American courts in a vast array of individual scenarios. In some cases, although courts have ruled against teachers based on procedural errors in their execution of academic freedom, the right to academic freedom itself has been extrapolated from protection afforded teachers under the First Amendment. Where academic freedom most often fails lies in expression that contrasts regulations governing minors in other aspects of society, as in Fowler v. Board of Education. As further tests of academic freedom in courts are likely inevitable, the path to its promotion may lie in navigating the narrow channel between teachers' compliance as subordinates and protecting the rights already reserved for minors.
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