Haywood v. Drown
Annotate this Case
556 U.S. 729 (2009)
OCTOBER TERM, 2008
HAYWOOD V. DROWN
SUPREME COURT OF THE UNITED STATES
HAYWOOD v. DROWN et al.
certiorari to the court of appeals of new york
No. 07–10374. Argued December 3, 2008—Decided May 26, 2009
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. 5–13.
(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. 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. 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 performed in 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. Pp. 5–8.
(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. 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. 8–13.
9 N. Y. 3d 481, 881 N. E. 2d 180, reversed and remanded.
Stevens, J., delivered the opinion of the Court, in which Kennedy, Souter, Ginsburg, and Breyer, JJ., joined. Thomas, J., filed a dissenting opinion, in which Roberts, C. J., and Scalia and Alito, JJ., joined as to Part III.