the issue becomes what to do about it. Plaintiffs in public forum cases generally seek a court order giving them access to the public place, but Bennett has not sought injunctive relief nor claimed that she is entitled to operate a major event on the Courthouse Plaza in the future. She simply asks us to remand the case to the trial court for a determination of damages. Under the facts of this case, however, we cannot find as a matter of law that Bennett is entitled to damages. ¶ 30 Although we find Bennett’s rights under the First Amendment were violated, “no compensatory damages [can] be awarded for a violation of [those] right[s] absent proof of actual injury.” Memphis Cmty. Sch. Dist. v. Stachura, 477 U.S. 299, 308-11, 106 S.Ct. 2537, 91 L.Ed.2d 249 (1986) (emphasis omitted) (<HOLDING>). Bennett presents a plausible argument that
holding that damages based on the abstract value of constitutional rights are not a permissible element of compensatory damages in action under civil rights act of 1871 holding that damages based on the abstract value or importance of constitutional rights are not a permissible element of compensatory damages in such cases holding that punitive damages do not need to be proportional to compensatory damages holding that when compensatory damages are nominal a much higher ratio of punitive damages to compensatory damages can be contemplated holding that punitive damages which are based on the same underlying action justifying nondischargeability of compensatory damages are likewise nondischargeable