SCOTUS: States can't bar jurisdiction over § 1983 claims in state court

The Supreme Court held 5-4 that a state may not exclude a class of claims under 42 U.S.C. § 1983 from its state courts when those courts entertain analogous claims based on state law.

Justice Stevens wrote for the Court that a New York law divesting courts of jurisdiction over § 1983 claims against prison officials, and permitting only limited suits against the state itself in a court of claims, is “effectively an immunity statute cloaked in jurisdictional garb,” and violates the Supremacy Clause. Justice Thomas wrote a dissent, which Justices Roberts, Alito and Scalia joined in part. Haywood v. Drown, --- S.Ct. ----, 2009 WL 1443136 (May 26, 2009) (No. 07-10374).

 

          N.Y. Corrections Law§ 24 creates an exception to the general jurisdiction of the state’s trial courts (called “supreme courts”). It withdraws jurisdiction over claims against prison officials; instead, prisoners may only sue the state itself in the court of claims, and may only obtain compensatory damages (not injunctive relief, punitive damages or attorneys’ fees). Haywood asserted § 1983 claims against prisoner officers, and the state’s highest court affirmed dismissal 4-3. The U.S. Supreme Court reversed.

 

          The Court has long held that the Supremacy Clause mandates state court jurisdiction over federal claims, unless (1) Congress withdraws such jurisdiction, or (2) the state limits jurisdiction pursuant to “a neutral state rule regarding the administration of the courts.” Howlett v. Rose, 496 U. S. 356 (1990). In previous cases, the Court has overturned state laws that singled out federal claims for jurisdiction-stripping or grants of immunity. The state argued that § 24 was a “neutral rule” of judicial administration because it barred state and federal claims alike. The Court disagreed, stating that “equality of treatment” between state and federal law is necessary, but not sufficient under the Supremacy Clause.  “A jurisdictional rule cannot be used as a device to undermine federal law,” the Court said, “no matter how evenhanded it may appear.” Although state law damages claims against prison officers were similarly barred under § 24, analogous claims – for example, injunctive relief claims against prisoner officers, or damages claims against police officers – were permitted. Moreover, section 24 had the practical effect of granting virtual immunity to prison officers. Thus, it was clear that the law’s purpose and effect was to undermine the substance of federal law. “[H]aving made the decision to create courts of general jurisdiction that regularly sit to entertain analogous suits,” the Court concluded, “New York is not at liberty to shut the courthouse door to federal claims that it considers at odds with its local policy.”

 

          The Court’s ruling thus (a) reaffirms the rule that state courts of general jurisdiction therefore must recognize jurisdiction over federal claims to the same extend as claims under state law, and (b) extends that rule, so that states may not place jurisdictional limits on federal claims that have the effect of immunizing federal law-breakers or undermining substantive federal policy. Although New York’s law targeted claims by prisoners against individual officers, one employment scholar has noted that the ruling could also have implications for states’ attempts to limit claims by state employees by channeling them into special agencies or tribunals.

 

          Speaking only for himself, Justice Thomas argued at length that the Court’s longstanding holding that state courts must entertain federal claims is at odds with the original meaning of the Constitution. In his view, “the States have unfettered authority to determine whether their local courts may entertain a federal cause of action.” Based on his reading of the history of the adoption of the supremacy Clause, Thomas argued that the clause’s “exclusive function is to disable state laws that are substantively inconsistent with federal law—not to require state courts to hear federal claims over which the courts lack jurisdiction.” Thomas would therefore abandon most of the Court’s relevant jurisprudence, starting with McKnett v. St. Louis & San Francisco R. Co., 292 U. S. 230 (1934).

 

          In the part of his dissent joined by three other justices, Thomas argued that even under existing precedent, states are merely forbidden to discriminate against federal claims through jurisdictional rules. Because § 24 treated identical state and federal claims equally, it was constitution. Thomas concluded that the majority had “transformed a single exception to the rule of state judicial autonomy into a virtually ironclad obligation to entertain federal business.”