The following excerpt is from Newman v. Board of Ed. of City School Dist. of New York, 594 F.2d 299 (2nd Cir. 1979):
5 Compensable damages are also available under 1983 for mental or emotional distress caused by a denial of procedural due process. There must be proof, however, that such injury actually was caused by the denial. Carey v. Piphus, 435 U.S. 247, 264, 98 S.Ct. 1042, 55 L.Ed.2d 252 (1978).
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