Haywood v. Drown
Divided court rules on Supremacy Clause challenge to New York law (May 26, 2009)
A divided Supreme Court held today that the State of New York may not prevent all private damages claims in state court against state correctional employees, including claims under federal civil rights law.
The case concerns Keith Haywood, a prisoner in a New York State correctional facility who brought two actions in New York State court against several correction officers for damages in connection with three disciplinary proceedings and an alleged altercation.
The trial court dismissed both complaints as barred by New York Correction Law §24, which provides that New York courts lack jurisdiction to entertain any private claim for damages against correction employees in their personal capacity for acts or omissions committed on the job. Such claims for damages may be brought directly against the State of New York in the New York State Court of Claims.
The New York State Appellate Division affirmed the dismissal of the claims. And in November 2007, the New York Court of Appeals further upheld the law, calling it “a neutral state rule regarding the administration of the courts.”
According to the narrow 4-3 majority: “if a state does not extend jurisdiction to its courts to litigate a certain type of claim, it may deprive those courts of jurisdiction over a related federal claim. In that situation, there is no Supremacy Clause violation because there is no discrimination against the federal claim in favor of similar state claims.”
In asking the Supreme Court to hear the case, Haywood argues that “the New York Court of Appeals’ decision is in severe tension with several decisions of this Court, affects many current and future litigants and – if unchecked – is likely to embolden other states to selectively close their courts to those federal rights with which they disagree or to impose other burdens simply by applying their substantive legislative policies to preclude or burden identical narrowly delineated state claims.”
On May 26, 2009, a divided Supreme Court reversed and remanded the lower court order in a 5-4 opinion by Justice John Paul Stevens.
"Having made the decision to create courts of general jurisdiction that regularly sit to entertain analogous suits, New York is not at liberty to shut the courthouse door to federal claims that it considers at odds with its local policy," Stevens wrote for the majority. "A State’s authority to organize its courts, while considerable, remains subject to the strictures of the Constitution."
Justice Clarence Thomas filed a dissenting opinion, joined in Part III by Chief Justice John G. Roberts Jr. and Justices Antonin Scalia and Samuel A. Alito.
"Neither the Constitution nor our precedent requires New York to open its courts to §1983 federal actions,"Thomas asserted.
Question presented:
Whether a state law barring state courts from hearing damages actions against corrections officers violates the Supremacy Clause by not permitting adjudication of claims under 42 USC 1983.