Haywood v. Drown
| Decision Date | 26 May 2009 |
| Docket Number | No. 07–10374.,07–10374. |
| Parties | Keith HAYWOOD, Petitioner, v. Curtis DROWN et al. |
| Court | U.S. Supreme Court |
OPINION TEXT STARTS HERE
Preempted
McKinney's Correction Law § 24
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. Thereunder, a prisoner will have his claim against a correction officer dismissed for want of jurisdiction and will be left to pursue a damages claim against the State in the Court of Claims, a court of limited jurisdiction in which the prisoner will not be entitled to attorney's fees, punitive damages, or injunctive relief. Petitioner 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 petitioner'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— i.e., neither can 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.
Held:Correction Law § 24, as applied to § 1983 claims, violates the Supremacy Clause. Pp. 2113 – 2118.
(a) Federal and state law “together form one system of jurisprudence, which constitutes the law of the land for the State; and the courts of the two jurisdictions are ... courts of the same country, having jurisdiction partly different and partly concurrent.” Claflin v. Houseman, 93 U.S. 130, 136–137, 23 L.Ed. 833. Both state and federal courts have jurisdiction over § 1983 suits. So strong is the presumption of concurrency that it is defeated only when Congress expressly ousts state courts of jurisdiction, see e.g., id., at 136; or “[w]hen a state court refuses jurisdiction because of a neutral state rule regarding the administration of the courts,” Howlett v. Rose, 496 U.S. 356, 372, 110 S.Ct. 2430, 110 L.Ed.2d 332. As to whether a state law qualifies as such a neutral rule, States retain substantial leeway to establish the contours of their judicial systems, but lack authority to nullify a federal right or cause of action they believe is inconsistent with their local policies. Whatever its merits, New York's policy of shielding correction officers from liability when sued for damages arising out of conduct performedin the scope of their employment is contrary to Congress' judgment that all persons who violate federal rights while acting under color of state law shall be held liable for damages. “A State may not ... relieve congestion in its courts by declaring a whole category of federal claims to be frivolous.” Id., at 380, 110 S.Ct. 2430. Pp. 2113 – 2116.
(b) The New York Court of Appeals' holding was based on the misunderstanding that Correction Law § 24's equal treatment of federal and state claims would guarantee that the statute would pass constitutional muster. Although the absence of discrimination is essential to this Court's finding a state law neutral, nondiscrimination alone is not sufficient to guarantee that a state law will be deemed neutral. In addition to this misplaced reliance on equality, respondents mistakenly treat this case as implicating the “great latitude [States enjoy] to establish the structure and jurisdiction of their own courts.” Howlett, 496 U.S., at 372, 110 S.Ct. 2430. However, this Court need not decide whether Congress can compel a State to offer a forum, otherwise unavailable under state law, to hear § 1983 suits, because New York has courts of general jurisdiction that routinely sit to hear analogous § 1983 actions. Pp. 2115 – 2118.
9 N.Y.3d 481, 851 N.Y.S.2d 84, 881 N.E.2d 180, reversed and remanded.
Jason E. Murtagh, for Petitioner.
Barbara D. Underwood, for Respondents.
Nory Miller, Dechert LLP, Philadelphia, PA, Jason Murtagh, Gary Mennitt, Elisa Wiygul, Dechert LLP, Philadelphia, PA, for Petitioner.
Andrew M. Cuomo, Attorney General, Barbara D. Underwood, Solicitor General, Andrea Oser, Deputy Solicitor General, Nancy A. Spiegel, Senior Assistant Solicitor General, Robert M. Goldfarb, Assistant Solicitor General, New York, New York, for Respondents.
In our federal system of government, state as well as federal courts have jurisdiction over suits brought pursuant to 42 U.S.C. § 1983, the statute that creates a remedy for violations of federal rights committed by persons acting under color of state law.1 While that rule is generally applicable to New York's supreme courts—the State's trial courts of general jurisdiction— New York's Correction Law § 24 divests those courts of jurisdiction over § 1983 suits that seek money damages from correction officers. New York thus prohibits the trial courts that generally exercise jurisdiction over § 1983 suits brought against other state officials from hearing virtually all such suits brought against state correction officers. The question presented is whether that exceptional treatment of a limited category of § 1983 claims is consistent with the Supremacy Clause of the United States Constitution.2
Petitioner, an inmate in New York's Attica Correctional Facility, commenced two § 1983 actions against several correction employees alleging that they violated his civil rights in connection with three prisoner disciplinary proceedings and an altercation. Proceeding pro se, petitioner filed his claims in State Supreme Court and sought punitive damages and attorney's fees. The trial court dismissed the actions on the ground that, under N.Y. Correct. Law Ann. § 24 (West 1987) (hereinafter Correction Law § 24), it lacked jurisdiction to entertain any suit arising under state or federal law seeking money damages from correction officers for actions taken in the scope of their employment. The intermediate appellate court summarily affirmed the trial court. 35 App.Div.3d 1290, 826 N.Y.S.2d 542 (2006).
The New York Court of Appeals, by a 4–to–3 vote, also affirmed the dismissal of petitioner's damages action. The Court of Appeals rejected petitioner's argument that Correction Law § 24's jurisdictional limitation interfered with § 1983 and therefore ran afoul of the Supremacy Clause of the United States Constitution. The majority reasoned that, because Correction Law § 24 treats state and federal damages actions against correction officers equally (that is, neither can be brought in New York courts), the statute should be properly characterized as a “neutral state rule regarding the administration of the courts” and therefore a “valid excuse” for the State's refusal to entertain the federal cause of action. 9 N.Y.3d 481, 487, 851 N.Y.S.2d 84, 881 N.E.2d 180, 183, 184 (2007) (quoting Howlett v. Rose, 496 U.S. 356, 369, 372, 110 S.Ct. 2430, 110 L.Ed.2d 332 (1990) (internal quotation marks omitted)). The majority understood our Supremacy Clause precedents to set forth the general rule that so long as a State does not refuse to hear a federal claim for the “sole reason that the cause of action arises under federal law,” its withdrawal of jurisdiction will be deemed constitutional. 9 N.Y.3d, at 488, 851 N.Y.S.2d 84, 881 N.E.2d, at 184. So read, discrimination vel non is the focal point of Supremacy Clause analysis.
In dissent, Judge Jones argued that Correction Law § 24 is not a neutral rule of judicial administration. Noting that the State's trial courts handle all other § 1983 damages actions,he concluded that the State had created courts of competent jurisdiction to entertain § 1983 suits. In his view, “once a state opens its courts to hear section 1983 actions, it may not selectively exclude section 1983 actions by denominating state policies as jurisdictional.” Id., at 497, 851 N.Y.S.2d 84, 881 N.E.2d, at 191.
Recognizing the importance of the question decided by the New York Court of Appeals, we granted certiorari. 554 U.S. 902, 128 S.Ct. 2938, 171 L.Ed.2d 863 (2008). We now reverse.
Motivated by the belief that damages suits filed by prisoners against state correction officers were by and large frivolous and vexatious, New York passed Correction Law § 24.3 The statute employs a two-step process to strip its courts of jurisdiction over such damages claims and to replace those claims with the State's preferred alternative. The provision states in full:
Thus, under this scheme, a prisoner seeking damages from a correction officer will have his claim dismissed for want of jurisdiction and will be 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.4 See N.Y. Const., Art. VI, § 9;...
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