Felder v. Casey
Annotate this Case
487 U.S. 131 (1988)
U.S. Supreme Court
Felder v. Casey, 487 U.S. 131 (1988)
Felder v. Casey
Argued March 28, 1988
Decided June 22, 1988
487 U.S. 131
Nine months after being allegedly beaten by Milwaukee police officers who arrested him on a disorderly conduct charge that was later dropped, petitioner filed this state court action against the city and certain of the officers under 42 U.S.C. § 1983, alleging that the beating and arrest were racially motivated, and violated his rights under the Fourth and Fourteenth Amendments to the Federal Constitution. The officers (respondents) moved to dismiss the suit because of petitioner's failure to comply with Wisconsin's notice of claim statute, which provides, inter alia, that before suit may be brought in state court against a state or local governmental entity or officer, the plaintiff, within 120 days of the alleged injury, must notify the defendant of the circumstances and amount of the claim and the plaintiff's intent to hold the named defendant liable; that the defendant then has 120 days to grant or disallow the requested relief; and that the plaintiff must bring suit within six months of receiving notice of disallowance. The court denied the motion as to petitioner's § 1983 claim, and the Wisconsin Court of Appeals affirmed. The Wisconsin Supreme Court reversed, holding that, while Congress may establish the procedural framework under which claims are heard in federal courts, States retain the authority under the Constitution to prescribe procedures that govern actions in their own tribunals, including actions to vindicate congressionally created rights.
Held: Because the Wisconsin notice of claim statute conflicts in both its purpose and effects with § 1983's remedial objectives, and because its enforcement in state court actions will frequently and predictably produce different outcomes in § 1983 litigation based solely on whether the claim is asserted in state or federal court, it is preempted pursuant to the Supremacy Clause when the § 1983 action is brought in a state court. Pp. 487 U. S. 138-153.
(a) Unlike the lack of statutes of limitations in the federal civil rights laws -- which has led to borrowing state law limitations periods for personal injury claims -- the absence of any federal notice of claim provision is not a deficiency requiring the importation of such a state law provision into the federal civil rights scheme. Notice of claim rules are neither universally familiar nor in any sense indispensable prerequisites to litigation, and there is thus no reason to suppose that Congress intended federal courts to apply such rules, which significantly inhibit the ability to
bring federal actions. With regard to federal preemption (as opposed to adoption) of state law, application of the notice requirement burdens the exercise of the federal right by forcing civil rights victims who seek redress in state courts to comply with a requirement that is absent from civil rights litigation in federal courts. Moreover, enforcement of such statutes in state court § 1983 actions will frequently and predictably produce different outcomes in federal civil rights litigation based solely on whether the litigation takes place in state or federal court. Pp. 487 U. S. 139-141.
(b) Wisconsin's notice of claim statute undermines § 1983's unique remedy against state governmental bodies and their officials by conditioning the right of recovery so as to minimize governmental liability. The state statute also discriminates against the federal right, since the State affords the victim of an intentional tort two years to recognize the compensable nature of his or her injury, while the civil rights victim is given only four months to appreciate that he or she has been deprived of a federal constitutional or statutory right. Moreover, the notice provision operates, in part, as an exhaustion requirement by forcing claimants to seek satisfaction in the first instance from the governmental defendant. Congress never intended that those injured by governmental wrongdoers could be required, as a condition of recovery, to submit their claims to the government responsible for their injuries. Pp. 487 U. S. 141-142.
(c) Wisconsin has chosen, through its legislative scheme governing citizens' rights to sue the State's subdivisions, to expose its subdivisions to large liability and defense costs, and has made the concomitant decision to impose notice conditions that assist the subdivisions in controlling those costs. The decision to subject state subdivisions to liability for violations of federal rights, however, was a choice that Congress made, and it is a decision that the State has no authority to override. That state courts will hear the entire § 1983 cause of action once a plaintiff complies with the notice statute does not alter the fact that the statute discriminates against the precise type of claim Congress has created. Pp. 487 U. S. 142-145.
(d) While prompt investigation of claims inures to the benefit of both claimants and local governments, notice statutes are enacted primarily for the benefit of governmental defendants, and are intended to afford such defendants an opportunity to prepare a stronger case. Sound notions of public administration may support the prompt notice requirement, but those policies necessarily clash with the remedial purposes of the federal civil rights laws. Pp. 487 U. S. 145-146.
(e) Patsy v. Board of Regents of Florida, 457 U. S. 496, which held that plaintiffs need not exhaust state administrative remedies before instituting § 1983 suits in federal court, is not inapplicable to this state court suit on the theory, asserted by the Wisconsin Supreme Court, that
States retain the authority to prescribe the rules and procedures governing suits in their courts. That authority does not extend so far as to permit States to place conditions on the vindication of a federal right. Congress meant to provide individuals immediate access to the federal courts, and did not contemplate that those who sought to vindicate their federal rights in state courts could be required to seek redress in the first instance from the very state officials whose hostility to those rights precipitated their injuries. There is no merit to respondents' contention that the exhaustion requirement imposed by the Wisconsin statute is essentially de minimis, because the statutory settlement period entails none of the additional expense or undue delay typically associated with administrative remedies, and does not alter a claimant's right to seek full compensation through suit. Moreover, to the extent the exhaustion requirement is designed to sift out "specious claims" from the stream of complaints that can inundate local governments in the absence of immunity, such a policy is inconsistent with the aims of the federal legislation. Pp. 487 U. S. 146-150.
(f) Application of Wisconsin's statute to state court § 1983 actions cannot be approved as a matter of equitable federalism. Just as federal courts are constitutionally obligated to apply state law to state claims, 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. A state law that predictably alters the outcome of § 1983 claims depending solely on whether they are brought in state or federal court within the State is obviously inconsistent with the federal interest in intrastate uniformity. Pp. 487 U. S. 150-153.
139 Wis.2d 614, 408 N.W.2d 19, reversed and remanded.
BRENNAN, J., delivered the opinion of the Court, in which WHITE, MARSHALL, BLACKMUN, STEVENS, SCALIA, and KENNEDY, JJ., joined. WHITE, J., filed a concurring opinion, post, p. 487 U. S. 153. O'CONNOR, J., filed a dissenting opinion, in which REHNQUIST, C.J., joined, post, p. 487 U. S. 156.
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