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Based on the legislative histories of both 42 U.S.C.S. § 1983 and 42 U.S.C.S. § 1997e, exhaustion of state administrative remedies should not be required as a prerequisite to bringing an action pursuant to 42 U.S.C.S. § 1983.
Petitioner Georgia Patsy filed an action in Federal District Court under 42 U. S. C. § 1983 for declaratory or injunctive relief or damages, alleging that respondent Florida International University had denied her employment opportunities solely on the basis of her race and sex. The District Court granted respondent's motion to dismiss because petitioner had not exhausted available state administrative remedies. The Court of Appeals vacated, holding that a § 1983 plaintiff could be required to exhaust administrative remedies if certain specified conditions were met, and remanded the case to the District Court to determine whether exhaustion would be appropriate in the instant case.
Was exhaustion of state administrative remedies a prerequisite to an action under 42 U. S. C. § 1983?
The Supreme Court reversed the decision of the lower courts, holding that exhaustion of administrative remedies was not a prerequisite to a § 1983 action because Congress assigned to the courts the role of protecting constitutional rights and did not intend under most circumstances for civil rights claims to be initially addressed through state administrative procedures. The Court concluded that, in enacting § 1 of the Civil Rights Act of 1871, 17 Stat. 13, Congress designated the courts for redress of constitutional claims, and Congress did not intend to expand the exhaustion requirement when, under 42 U.S.C.S. § 1997e, it limited administrative remedies to 42 U.S.C.S. § 1983 claims brought by adult convicts. Therefore, the petitioner was not required to exhaust state remedies to pursue her claim.