Haywood v. Drown
Issues
Whether a state may constitutionally withdraw jurisdiction over 42 U.S.C. § 1983 civil actions filed in state courts against state corrections officers.
While Keith Haywood was serving a prison sentence for his second felony conviction, corrections officers filed two separate misbehavior reports against him. After Haywood was found guilty of both offenses, he sued several corrections officers, including the hearing officers who heard his case, in civil lawsuits. Haywood asserted several claims under 42 U.S.C. § 1983. The New York Supreme Court dismissed Haywood’s claims on the basis of New York Corrections Law § 24, which prohibits suits against individual state corrections officers rather than against the state itself. The Appellate Division and the New York Court of Appeals affirmed. Haywood is now appealing to the Supreme Court of the United States. His case will determine whether a state has the sovereign authority to withdraw jurisdiction over an area of federal law. The Supreme Court’s decision will also affect New York corrections officers, who, at present, are immune to suits arising in the course of their jobs. In reaching its decision, the Court will have to balance the efficiency concerns the corrections officers raise with the fairness concerns that Haywood and his supporters raise.
Questions as Framed for the Court by the Parties
Whether a state’s withdrawal of jurisdiction over certain damages claims against state corrections employees — from state courts of general jurisdiction — may be constitutionally applied to exclude federal claims under Section 1983, especially when, as here, the state legislature withdrew jurisdiction because it concluded that permitting such lawsuits is bad policy?
In 1992, Keith Haywood received a fifteen- to thirty-year sentence in Attica Correctional Facility for his second violent felony. See Haywood v. Drown, 9 N.Y.3d 481, 484 (N.Y. 2007); see also People v.
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Additional Resources
· Oyez
· PrawfsBlawg: A blog post from before the Supreme Court granted cert, arguing that the Court should do so.
· Constitutional Law: Check out more about the Supremacy Clause here.