Williams v. Washington

LII note: The U.S Supreme Court has now decided Williams v. Washington

Issues

Must claimants exhaust required state administrative remedies to bring claims under 42 U.S.C. § 1983 in state court?

Oral argument:
October 07, 2024
Court below:
Supreme Court of Alabama

This case asks the Supreme Court to decide whether it is necessary for claimants to exhaust state remedies before bringing a claim under 42 U.S.C. § 1983 in state court. Williams, et al. argue that the language of § 1983 and the Supremacy Clause compel states to hear § 1983 claims. Washington counters that state sovereignty allows states to create laws about their own courts’ jurisdiction regardless of whether this denies certain federal claims. This case has serious implications for plaintiffs’ choice of forum when bringing a § 1983 claim and on the allocation of power between state and federal governments.

Questions as Framed for the Court by the Parties

Whether exhaustion of state administrative remedies is required to bring claims under 42 U.S.C. § 1983 in state court.

Facts

In 1871, Congress enacted § 1983 of the Civil Rights Act of 1871 to create a right of action for individuals to sue state officials for violations of their civil rights and safeguard citizens from discrimination caused by state law. Federal courts maintain original jurisdiction over civil rights brought under § 1983. Courts have widely accepted that state courts are compelled to hear § 1983 cases under the Supremacy Clause. Courts have also often assumed that jurisdiction exists where a state statute confers jurisdiction over a state claim that is analogous to a federal claim under § 1983.

In 2022, Aaron Johnson, along with 26 other plaintiffs, brought § 1983 claims against the Alabama Department of Labor in Montgomery Circuit Court regarding their delayed unemployment applications. From April 2020 through March 2022, the Alabama Department of Labor faced over one million applications because of the COVID-19 pandemic. Because these requests greatly outnumbered the typical number of applications that the Department faced, it struggled to process them in a timely manner.

Johnson sought a speedier application approval process and sued Fitzgerald Washington, the Alabama Secretary of Labor. The suit included multiple claims for injunctive relief , which would force the state to take certain actions such as approve the applications promptly and pay all of the claims. The suit also argued that the unemployment application process in Alabama violated the Fourteenth Amendment Due Process Clause and the Social Security Act of 1935 . Each of these constituted federal claims brought under § 1983.

Secretary Washington then moved to dismiss the claims on the grounds that the circuit court lacked subject-matter jurisdiction , and that the plaintiff both did not have a valid cause of action and lacked substantial evidentiary support for his claims. The circuit court dismissed the case, so Johnson appealed to the Supreme Court of Alabama .

In June of 2023, the Alabama Supreme Court affirmed the circuit court’s dismissal and determined that the circuit court lacked subject-matter jurisdiction. The court’s determination rested on the idea that Johnson could not seek relief for the unemployment applications without first exhausting state administrative remedies . The court rejected the idea that § 1983 preempted exhaustion requirements or compelled state courts to hear a claim without following their usual requirements for subject matter jurisdiction.

In August 2023, Nancy Williams, now the named party for the petitioners, filed a petition for writ of certiorar i with the Supreme Court of the United States appealing the Alabama Supreme Court decision. The petition questions whether the exhaustion of state administrative remedies is necessary to raise § 1983 claims in a state court. On January 12, 2024, the Supreme Court granted certiorari.

Analysis

INTERPRETING 42 U.S.C. § 1983

Williams argues that a state court cannot require a plaintiff to first exhaust administrative remedies before bringing a claim under 42 U.S.C. § 1983 . Williams contends that Supreme Court precedent interprets § 1983 as prohibiting states from enforcing their exhaustive remedy requirements in both federal and state courts. Williams asserts that the same considerations which gave rise to Patsy v. Board of Regents , a § 1983 claim in federal court, apply in state court suits. For example, Williams contends that Congress could not have intended to require plaintiffs to seek relief from the same state officials whose actions allegedly caused their injuries. In support, Williams cites Patsy , which characterizes state administrative proceedings as barriers to remedies in a § 1983 action and considered Congress’s mistrust of state institutions’ fact-finding processes at the time of § 1983’s enactment. Williams also emphasizes that a plaintiff has access to both the state and the federal system to pursue their § 1983 claim and seek relief. To advance this dual system and promote the federal interest in intrastate uniformity, Williams maintains that the outcome of a § 1983 claim should not depend on whether it was brought in state or federal court.

Secretary Washington contends that, because preemption intrudes on a state’s sovereignty , the Supreme Court disfavors applying preemption in areas of historic state powers. For that reason, Washington argues that all preemption arguments must be grounded in the text and structure of the relevant federal statute. The Secretary asserts that, while Patsy interpreted § 1983 to not require exhaustion, the statute does not forbid exhaustion requirements either. The Secretary emphasizes that Patsy only held that, because Congress did not include an exhaustion requirement, the courts should not impose their own. The Secretary maintains that Patsy says nothing about exhaustion that is legislatively imposed by state law. The Secretary asserts that the text of § 1983 is flexible and not so comprehensive that it lacks room for supplementary state legislation. The Secretary contends that even if the Court looks to the congressional purpose of the statute, it would find that Congress did not contemplate exhaustion requirements when it enacted § 1983 because such requirements were unheard of at the time. The Secretary further argues that neither § 1983 nor Patsy expressly call for preemption. Preemption, the Secretary asserts, arises from the conflict between the purposes and effects of Alabama’s exhaustion requirement and the objectives of § 1983. Because preemption depends on the purposes and effects of the Alabama exhaustion requirement, the Secretary concludes that courts can draw no clear-line preemption rule.

“JURISDICTIONAL” AND THE NEUTRAL STATE RULE

Williams contends that the Supreme Court of Alabama incorrectly held that state courts may impose jurisdictional rules that allow them to refuse to open their courts to federal claims. Williams asserts that state courts must apply federal law when the claimant brings a federal claim in state court, even if federal law compels states to hear federal cases. Williams argues that, although the Supreme Court of Alabama called the exhaustion requirement jurisdictional, the Supreme Court has held that a court cannot rely on a jurisdictional policy to withhold a forum for adjudication of a federal cause of action. Otherwise, Williams points out, jurisdictional policies would provide a way for states to circumvent prior Supreme Court decisions and avoid upholding federal laws. Williams recognizes that a state court may decline to follow federal law if the state instead applies a neutral procedural rule on the administration of the courts. However, Williams asserts that a state may not do so when those rules are preempted by federal law. Williams argues that Alabama’s exhaustion requirement is not a neutral rule on the administration of the courts because it applies only to unemployment disputes with the Department of Labor. Williams further contends that courts cannot trigger the neutral rule exception when a state statute, as William asserts Alabama’s statute does here, results in the dismissal of a claim that would have survived had the case been filed in federal court.

The Secretary contends that states need the power to define the jurisdiction of their own courts. The Supreme Court, the Secretary points out, relies on state courts to enforce federal law with the consent of the states. The Secretary further argues that Alabama’s exhaustion requirement is a neutral jurisdictional rule concerned with an adjudicator’s competence over the subject matter of cases involving unemployment compensation. The requirement is not, the Secretary asserts, a contrived immunity for state actors or an attempt to escape civil rights laws. The Secretary emphasizes that Alabama’s statute applies without regard to the identity of the party, whether it be an agency, an employer, or a person seeking benefits. Although the statute only applies to a particular class of claims—unemployment benefit disputes with the Department of Labor—the Secretary contends that the rule is neutral because it applies equally to suits arising under federal or state law. For jurisdictional rules, the Secretary asserts, the rule must only apply equally to precise comparators and not universally. Further, the Secretary submits that a state court’s exercise of jurisdiction does not undermine § 1983’s uniform application because the ultimate disposition of the case is unaffected, the appeal to state court is simply postponed.

ALABAMA’S EXHAUSTION REQUIREMENT AND § 1983

Williams submits that a § 1983 claim never requires, as a categorical rule, administrative exhaustion. However, Williams asserts that, even if the Court adopts a law-by-law analysis, Alabama’s exhaustion requirement has served as an obstacle to the accomplishment and execution of Congress’s objectives and purposes and should be preempted. Williams argues that, because many of the § 1983 claims at issue are founded on the Alabama Department of Labor’s alleged failure to conduct the processes for administrative remedies in a timely manner, requiring plaintiffs to first exhaust state law administrative remedies acts to bar their federal claims. Williams elaborates that the only alternatives are to wait years to challenge the delays through the administrative appeal process, which Williams calls an absurd result, or to bring their claims in federal court. To the latter, Williams again suggests the intention of Congress to provide plaintiffs with access to both court systems.

The Secretary argues that, when the Court analyzes the circumstances of the case instead of applying a categorical rule of preemption, Alabama’s exhaustion requirement does not present an obstacle to persons claiming unemployment compensation benefits. The Secretary contends that Felder v. Casey represents a case where such an analysis was performed by the Court, rather than a categorical application as Williams argues. While the Secretary acknowledges that the Department of Labor has the exclusive jurisdiction to make determinations, so long as the person appealing has exhausted their administrative remedies, they may appeal the Department’s decision in state court. The administrative process, the Secretary asserts, is not an obstacle to adjudicating claims; it is a means for adjudicating claims. Further, the Secretary contends that the state provided additional means that Williams and others could have used to exhaust their claims, but which they skipped without explanation. The Alabama rule, the Secretary emphasizes, does not conflict with the purpose of § 1983, providing plaintiffs an opportunity to adjudicate their claims and holding state officials who have violated federal law liable for their actions.

Discussion

IMPACTS ON PLAINTIFF’S COURT CHOICE

The Chamber of Commerce of the United States (“The Chamber”), in support of Williams, argues that exhaustive remedy requirements harm the ability to bring § 1983 claims in state court, creating duplicative litigation across state and federal courts. The Chamber warns that groups—like businesses and trade associations—seeking § 1983 relief typically also seek injunctions , which often cannot be granted in federal court. This, in turn, increases litigation costs, time and risks. Public Citizen and American Civil Liberties Union (“Public Citizen”), in support of Williams, note a similar necessity of bringing § 1983 claims in state court when brought in conjunction with state tort claims, such as in police misconduct suits. The Islam and Religious Freedom Action Team and American Hindu Coalition (“IRF), in support of Williams, argue that parties are forced into bringing their claims in state courts due to abstention doctrines , which bar federal courts from considering cases with ongoing state investigations. IRF cautions that if abstention doctrines force claims into state court while exhaustive remedy requirements impede the ability to bring claims in state court, some plaintiffs might altogether lose out on relief.

Tennessee and 15 Other States (“Tennessee”), in support of Washington, argue that states retain the right to create local laws which remove power from their state courts to hear a case, even if the result in that plaintiffs end up in a particular forum. Because federal courthouses exist as a forum in every state, Tennessee asserts that there is no party that would be unable to bring a claim locally. Tennessee emphasizes that claims like Williams’s remain viable in federal and state court after the plaintiff exhausts the state administrative remedies required by state law. Tennessee also notes Alabama’s exhaustion requirement laws do not target all § 1983 claims, but simply impose restrictions on the administration of unemployment benefits, so the requirements do not impact the forum for many § 1983 suits at all. Tennessee rejects the necessity to provide an abundance of forum options when other forums exist for plaintiffs to bring § 1983 claims.

IMPACTS OF SHIFTING POWER TO THE STATES

The National Health Law Program, in support of Williams, points out that granting state legislatures the ability to limit § 1983 proceedings gives those officials the power to impede plaintiffs seeking justice for their federal rights. The Constitutional Accountability Center (“CAC”), in support of Williams, asserts that exhaustive remedy requirements grant a dangerous power to state officials to handicap claims against themselves, given that § 1983 acts as the route to relief from state officials. The IRF posits that exhaustive remedy requirements also allow state officials to target groups, like religious minority groups, with little to no resources for lengthy litigation. These groups typically operate on strict budgets and especially lesser-known religious groups struggle to secure free counsel, meaning they suffer at the hands of unending legal procedures. .  IRF cautions that where states can maintain administrative proceedings until the plaintiffs are worn down or unable to bear the continuing costs the state can essentially bar relief for some plaintiffs.

Tennessee counters that barring state officials from developing their own jurisdiction requirements creates an overly powerful federal legislature. Because states are sovereign entities, Tennessee notes that states maintain the power to create jurisdictional limits via exhaustive remedy requirements. Tennessee worries that the legislature forcing a state judge to adjudicate federal claims when that state has chosen to limit their own adjudicatory power infringes on principles of federalism . Tennessee warns that, because the Constitution only confers Congress the power to make decisions about their own federal courts, allowing otherwise confers a dangerous amount of additional power over state courts’ jurisdiction typically prevented by federalism principles. Tennessee also maintains that reading the Supremacy Clause to grant jurisdiction to states where the state has not already conferred that jurisdiction grants the Supremacy Clause power far beyond that intended by the Constitution. Tennessee concludes that reading § 1983 as conferring such jurisdiction would give the federal government too much coercive power over the states.

Conclusion

Authors


Written by Sierra Berry and Sara Fischer

Edited by Alex Strohl

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