Law School Case Brief
Haywood v. Drown - 556 U.S. 729, 129 S. Ct. 2108 (2009)
In the United States federal system of government, state as well as federal courts have jurisdiction over suits brought pursuant to 42 U.S.C.S. § 1983, the statute that creates a remedy for violations of federal rights committed by persons acting under color of state law.
Believing that damages suits filed by prisoners against state correction officers were largely frivolous and vexatious, New York passed Correction Law § 24, which divested state courts of general jurisdiction of their jurisdiction over such suits, including those filed under 42 U.S.C. § 1983, and replaced those claims with the State's preferred alternative. As a result, a prisoner’s claim (Keith Haywood) against a correction officer, Curtis Drown, was dismissed for want of jurisdiction and he was left to pursue a damages claim against the State in the Court of Claims. In that court of limited jurisdiction, Haywood would not be entitled to attorney's fees, punitive damages, or injunctive relief. Haywood filed two § 1983 damages actions against correction employees in state court. Finding that it lacked jurisdiction under Correction Law § 24, the trial court dismissed the actions. Affirming, the State Court of Appeals rejected Haywood’s claim that the state statute's jurisdictional limitation violated the Supremacy Clause. It reasoned that because that law treats state and federal damages actions against correction officers equally since neither could be brought in New York courts, it was a neutral rule of judicial administration and thus a valid excuse for the State's refusal to entertain the federal cause of action.
Does N.Y. Correction Law § 24, as applied to damages actions under 42 U.S.C.S. § 1983, violate the Supremacy Clause of the Constitution?
On certiorari, the Supreme Court of the United States held that under the scheme of N.Y. Correct. Law § 24 (1987), Haywood seeking damages from Drown would have had his claim dismissed for want of jurisdiction and was left, instead, to pursue a claim for damages against an entirely different party (the State) in the Court of Claims--a court of limited jurisdiction. Under New York law, plaintiffs in the Court of Claims had to comply with a 90-day notice requirement, were not entitled to a jury trial, had no right to attorney's fees, and could not seek punitive damages or injunctive relief. The State's policy, whatever its merits, was contrary to Congress' judgment that all persons who violate federal rights while acting under color of state law were liable for damages under 42 U.S.C.S. § 1983. Contrary to the holding of the New York Court of Appeals, equality of treatment did not ensure that a state law was deemed a neutral rule of judicial administration and therefore a valid excuse for refusing to entertain a federal cause of action. Although the absence of discrimination was necessary to finding a state law neutral, it was not sufficient. Reversing, the Court held that N.Y. Correct. Law § 24, as applied to § 1983 claims, violates the Supremacy Clause, U.S. Const. art. VI, cl. 2.
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