In the 1992 case of Dale Farrar and Pat Smith, co-administrators of Estate of Joseph D. Farrar, Deceased v. William P. Hobby Jr., the U.S Supreme Court ruled on a matter concerning damages in civil rights lawsuits under Section 1983. The plaintiff's son had died while in police custody and they sued for $17 million but were awarded only $1 by the jury as nominal damages because there was no actual injury proven to have been caused by the defendant’s unconstitutional conduct. The court held that when a plaintiff seeks compensatory damages under Section 1983 but fails to prove actual injury from an alleged constitutional violation, he is entitled only to nominal damage awards without further justification or evidence required.

In the dissenting opinion for Dale Farrar and Pat Smith, Co-Administrators of Estate of Joseph D. Farrar, Deceased v. William P. Hobby Jr., Justice Blackmun argued that the majority's decision to deny damages was inconsistent with previous rulings on civil rights cases under Section 1983. He contended that nominal damages should be awarded even when actual harm cannot be proven because it serves as a symbolic vindication of constitutional rights violated by state officials' misconduct. Furthermore, he criticized the majority's reliance on common law principles in determining whether or not to award attorney’s fees in such cases; instead, he suggested focusing more on Congress’ intent behind enacting Section 1983 - which is to deter state officials from violating citizens' constitutional rights and provide remedies for victims who suffered such violations.