When a federal court exercises diversity or pendent jurisdiction over state-law claims, the outcome of the litigation in the federal court should be substantially the same, so far as legal rules determine the outcome of a litigation, as it would be if tried in a State court. Just as federal courts are constitutionally obligated to apply state law to state claims, so too the Supremacy Clause imposes on state courts a constitutional duty to proceed in such manner that all the substantial rights of the parties under controlling federal law are protected.
Nine months after a black individual was allegedly beaten by white police officers of the city of Milwaukee, Wisconsin, during his arrest on a subsequently dropped charge of disorderly conduct, the individual filed suit, under various state and federal laws including the civil rights provisions of 42 USCS 1983, against the city and several police officers in the Circuit Court of Milwaukee County, Wisconsin, and claimed that his beating and arrest (1) were unprovoked and racially motivated, and (2) violated his rights under the Fourth and Fourteenth Amendments to the United States Constitution. The officers moved to dismiss the suit for failure to comply with the notice-of-claim statute. The trial court granted the motion as to all state-law causes of action, but denied the motion as the individual's remaining federal claims. A state intermediate court of appeals affirmed, on the ground that the notice-of-claim statute was inapplicable to federal civil rights actions brought in state court. On appeal, the Wisconsin Supreme Court reversed. On certiorari, the United States Supreme Court reversed the judgment of the Wisconsin Supreme Court and remanded the case for further proceedings.
Was the Wisconsin statute requiring notice of claim prior to state-court suit against a local governmental entity or officer inapplicable to a 42 USCS 1983 action brought in state court?
The court found that the statute conflicted with the remedial objectives of § 1983, and that its enforcement in such actions would produce different outcomes in § 1983 litigation based solely on whether the claim was asserted in state or federal court. The court stated that the application of the notice requirement burdened the exercise of the federal right by forcing civil rights victims who sought redress in state courts to comply with a requirement that was entirely absent from civil rights litigation in federal courts. The court found that the notice provision impermissibly operated as an exhaustion requirement in that it forced claimants to seek satisfaction in the first instance from the governmental defendant.