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. In June, 2003, corrections officers filed two misbehavior reports regarding Haywood; one of the reports alleged that Haywood assaulted a corrections officer, and the other alleged that he had failed a urinalysis test. In two separate administrative hearings, Haywood was found guilty of each charge. About a year later, Haywood was also found guilty of improper mail solicitation.
Haywood then sued two employees of the New York State Department of Correctional Services (“DOCS”) in separate civil lawsuits in New York state court. The first suit was against defendant Curtis Drown, the DOCS hearing officer who had found Haywood guilty of improper mail solicitation. Haywood claimed that Drown had not given Haywood a fair and impartial hearing, that “his determination was based on insufficient evidence,” and that Drown had intended to violate Haywood’s First Amendment rights with the penalty Drown imposed. For relief, Haywood relied on 42 U.S.C. § 1983 to demand punitive damages and attorney’s fees; Haywood also demanded that the DOCS remove the misbehavior report from Haywood’s record.
Haywood’s other action against defendant Pat Smith, another DOCS hearing officer, and two corrections officers and two of their superior officers also relied on 42 U.S.C. § 1983. Haywood alleged that one of the corrections officers had caused a “minor injury to his left pinkie finger” and that the officer had then “conspired with his superiors to fabricate the facts set forth in his June 2003 misbehavior report.” In addition, Haywood alleged that DOCS employees had tampered with his June, 2003 urinalysis test and had denied Haywood a fair hearing.
The Office of the Attorney General of the State of New York represented Drown, Smith, and the other defendants. The defendants moved to dismiss Haywood’s complaints, arguing that New York’s Correction Law § 24 barred both Haywood’s state and federal claims.That statute prohibits New York courts of general jurisdiction from hearing certain civil actions against corrections officers; instead, the statute provides that such actions must be brought against the state of New York in the state's Court of Claims. On the basis of this statute, the Supreme Court of New York dismissed Haywood’s complaints, and the Appellate Division and the Court of Appeals both affirmed. Haywood then appealed to the Supreme Court of the United States, which granted certiorari on June 16, 2008.
According to New York Corrections Law § 24 (“NYCL § 24”), New York state courts lack jurisdiction to hear private civil actions seeking monetary damages against a Department of Corrections (“DOCS”) employee, in his or her personal capacity, if the action is related to acts or omissions that fall within the scope of employment. Such claims can only be brought as claims directly against the State of New York in New York’s Court of Claims. NYCL § 24 has an exception for claims brought by the attorney general on behalf of the state. New York’s Court of Claims is a court of limited jurisdiction that only hears claims brought against New York State.
The practical effect of NYCL § 24 is to bar from New York state courts all 42 U.S.C. § 1983 claims against DOCS employees in their personal capacity unless the plaintiff is seeking declaratory or injunctive relief only or if the conduct at issue falls outside of the scope of employment. Title 42, § 1983 claims cannot be heard in New York’s Court of Claims because 42 U.S.C. § 1983 allows suits against individuals only.
This case involves the validity of NYCL § 24 under the Supremacy Clause of the U.S. Constitution. According to the Supremacy Clause, when state and federal law conflict, federal law preempts state law. According to Haywood, the New York statute is unconstitutional under the Supremacy Clause because it directly conflicts with 42 U.S.C. § 1983. In contrast, Drown argues that NYCL § 24 does not violate the Supremacy Clause because the New York statute regulates the jurisdiction of state courts, an area of state control with which Congress did not intend 42 U.S.C. § 1983 to interfere.
Neutral Jurisdictional Rules and the Supremacy Clause
States can limit enforcement of a federal right without violating the Supremacy Clause if they have a “valid excuse” for doing so. ( One such excuse is when a state removes jurisdiction over federal claims by way of a “neutral state rule regarding the administration of the courts.” The New York Court of Appeals considered NYCL § 24 to be such a neutral jurisdictional rule and as a result, found no Supremacy Clause violation. to Drown, this determination by the highest court in New York is entitled to great deference. Furthermore, Drown argues that NYCL § 24 is jurisdictional in nature because it addresses state courts’ competence over subject matter, specifically the liability of certain state employees for conduct committed within the scope of their employment. According to Drown, decisions over what subject matter can be heard in what courts are the specific issues that “jurisdictional rules are designed to protect.” In addition, Drown argues that NYCL § 24 is clearly jurisdictional in nature because it assigns a particular subset of claims to a particular court, namely the New York Court of Claims.
However, Haywood argues that NYCL § 24 is a substantive rule, and not primarily jurisdictional in nature, and therefore is not immune from Supremacy Clause concerns. According to Haywood, to be considered a neutral jurisdictional rule, a statute must address the court’s “power over the person and competence over the subject matter.” Haywood argues that the New York statute is not related to the court’s competence over subject matter because NYCL § 24 removes only a small subset of claims from state court jurisdiction, leaving state courts with the authority to hear many claims of a similar nature. Furthermore, Haywood suggests the statute does not address the court’s power over the person because it leaves state courts responsible for claims almost identical to the ones barred by NYCL § 24, such as 42 U.S.C. § 1983 claims against non-DOCS state employees and all 42 U.S.C. § 1983 claims against state employees, including DOCS employees, that seek injunctive relief only or that involve conduct falling outside of the scope of their employment. According to Haywood, states cannot escape supremacy clause constitutional obligations “by the simple device of removing jurisdiction from courts otherwise competent.” For these reasons, Haywood argues that NYCL § 24 is not jurisdictional in nature but is rather an immunity statute for prison employees.
Drown also argues that the New York statute is a valid and neutral rule because it treats federal and state law claims the same. According to Drown, a state can limit the jurisdiction of its courts over federal claims without violating the Supremacy Clause as long as the state limits jurisdiction over analogous state law claims. The Court of Appeals of New York endorsed this “nondiscrimination principle” and held NYCL § 24 to be valid under the Supremacy Clause because it bars from state court both federal and state claims against DOCS employees in their personal capacity for conduct falling within the scope of employment.
According to Haywood, the Court of Appeals of New York erred in determining that the Supremacy Clause requires nothing more than treating state and federal claims alike. Such a test, Haywood argues, “turns the supreme law of the land into a menu from which states may freely pick and choose, depending on their own priority and views.” According to Haywood, the Supremacy Clause prevents a state from overriding federal law based on its “substantive disagreement” over federal priorities, even if it is done in such a way as to treat state and federal claims alike. In support of this argument, Haywood points to prior United States Supreme Court cases that struck down state laws that conflicted with federal priorities, even when the laws applied equally to state and federal claims.
State Policy Interests and Congressional Intent
Drown’s argument in support of NYCL § 24 emphasizes New York’s important policy interests behind the statute, including the “sound judicial and prison administration” of the state courts.According to Drown, courts have recognized that there are few issues more important to the state than administration of its prisons.
However, Haywood argues that state laws are invalid under the Supremacy Clause if they upset the purpose of the federal laws, regardless of the state interest served. According to Haywood, NYCL § 24 frustrates Congress’ purpose behind 42 U.S.C. § 1983, which was specifically to safeguard civil rights by allowing private parties to directly sue individuals who violated those rights. Furthermore, Haywood argues that NYCL § 24 further contravenes Congressional intent by limiting the remedies available to individuals who sue DOCS employees for conduct that falls within the scope of their employment. Cases in the New York Court of Claims are not heard before a jury trial and punitive damages, attorney’s fees, and other remedies that are otherwise available under 42 U.S.C. § 1983 are limited. As a result, Haywood argues, Congress’ efforts to provide for certain remedies through 42 U.S.C. § 1983 are less likely to be realized.
In contrast, Drown argues that NYCL § 24 does not contravene Congress’ intent because Congress did not intend 42 U.S.C. § 1983 to limit a state’s ability to control the jurisdiction of its courts. If 42 U.S.C. § 1983 was designed to have such an impact on state sovereignty, Drown argues, Congress would have had to make this intention clear in the language of the statute. , Since there is no such statement in 42 U.S.C. § 1983, according to Drown, the state maintains all rights to control the subject matter jurisdiction of its courts. Furthermore, Drown argues that NYCL § 24 does not run counter to Congress’ purpose behind 42 U.S.C. § 1983 because Congress intended federal courts to have a “paramount role” in the enforcement of those rights protected by the civil rights statute. Since NYCL § 24 does not limit the rights of individuals to bring suits against DOCS employees in federal court, where all the rights and remedies under 42 U.S.C. § 1983 are available, Drown argues that New York’s statute does not contravene Congressional intent.
Congress passed 42 U.S.C. § 1983 in 1871. In 1961, the Supreme Court made clear that the statute was an important tool for individuals to enforce their rights under the Fourteenth Amendment because individuals could sue governmental officials in federal courts even if the individuals would also have been able to sue the officials in state court. This way, individuals could avoid the potential bias of state courts. Because of this statute, “[u]ltimately, the federal court became the place to reform state governmental practices.”
State Sovereignty and the Supremacy Clause
The Supreme Court’s decision in Haywood v. Drown will determine the constitutionality of New York’s refusal to hear certain claims arising under 42 U.S.C. 1983. Drown and the other officers argue that the state of New York has “broad sovereign authority to establish the structure and subject matter jurisdiction of its own courts.” To rule for Haywood, the officers argue, would allow Congress to dictate jurisdiction where no such congressional power exists. The officers thus rely on the principle of federalism to bolster their defense.
Haywood relies on the principle of federalism as well. Prisoners’ Legal Services of New York (“PLSNY”) and other prisoners’ rights organizations argue that the New York law undermines federalism by depriving individuals, including prisoners, of the ability to bring civil rights claims in state courts. Thus, according to PLSNY, state courts would not be able to fulfill their proper role of adjudicating constitutional issues. Moreover, amici for Haywood argue that to rule in favor of the officers would contravene the Supremacy Clause of the U.S. Constitution.
Effect on Corrections Officers
In their brief to the Court of Appeals of New York, Drown and the other officers argued that the New York law allows corrections officers to do their work without being inhibited by “the threat of voluminous, vexatious and often meritless prisoner suits against them for damages.” Moreover, allowing the New York law to remain in place would permit corrections officers to do their work efficiently, because they would only be disrupted by legitimate claims against them.
In response, PLSNY and other organizations argue that the existence of a state law remedy against corrections officers would not inhibit those officers any more than the already-existing federal remedy against them. Moreover, other amici for Haywood argue that, as it exists now, the New York law creates an absolute immunity for corrections officers, whereas federal law only creates a partial immunity for corrections officers.
Efficiency Versus Fairness?
Finally, Drown and the other officers argue that allowing the New York law to stand is more efficient than holding that it is unconstitutional. After all, the officers argue, the state will pay any judgments that prisoners win against corrections officers anyway, so the prisoners might as well sue the state directly. Moreover, allowing the New York law to stand “relieves a drain on the finite resources of New York’s busy Supreme Court and diverts this litigation to the New York court with the exclusive function and special expertise in adjudicating damages claims against the State arising from the official conduct of state employees.”
Amici for Haywood argue that the New York law is, at its base, unfair. PLSNY argues that the law “favors one class of New York citizens, DOCS employees, over another, all other citizens.” A holding that the New York law is constitutional, PLSNY argues, would prevent civil rights victims from vindicating their rights under § 1983 and would thus contravene congressional intent. As a group of constitutional law professors put it, “[a] construction of the federal statute which permitted state immunity defense to have controlling effect would transmute a basic guarantee into an illusory promise.”
With this case the Supreme Court will further define the circumstances in which a state can withdraw jurisdiction over a certain area of federal law. The Court will also address the role of the Supremacy Clause as related to a state’s policy decisions to limit the jurisdiction of its courts. Directly, this decision will affect New York corrections officers, who, at present, are immune to suits arising in the course of their jobs. However, the Court’s decision in this case will likely effect many other classifications of defendants and plaintiffs with respect to their liability in state court to federal causes of action.