|Legal Intelligencer Blog
June 15, 2009
In its recent opinion issued in Haywood v. Drown, the U.S. Supreme Court clarified that a state legislature cannot remove the jurisdiction of certain of its courts to hear particular federal claims simply because the legislature finds those claims frivolous or vexatious. The case stemmed from the New York Legislature’s decision that, in its opinion, lawsuits against corrections officers for damages were too numerous, too frivolous or both. As a result, the Legislature enacted Corrections Law § 24, which stated that any claim against a state correctional officer for damages could only be brought in the New York Court of Claims, and even then only against the state – not the individual officer. This is a significant restriction, as plaintiffs in the Court of Claims have no right to a jury trial and cannot seek attorneys’ fees, punitive damages or injunctive relief.
The pertinent result of Corrections Law § 24 was to remove the jurisdiction of the New York Supreme Court – the state’s court of general, original jurisdiction – over claims asserted under 42 U.S.C. § 1983, the vehicle by which individuals can seek damages or injunctive relief against persons acting “under color of state law.” Thus, when an inmate in New York’s Attica Correctional Facility attempted to bring Section 1983 claims against several corrections employees in the New York Supreme Court his cases were dismissed by that court, and the dismissal upheld by the intermediate court and the New York Court of Appeals.
The U.S. Supreme Court reversed the Court of Appeals in a 5-4 decision. Justice John Stevens’ majority opinion noted that long-standing precedent holds that Section 1983 claims can generally be brought in either state or federal courts. New York’s attempt to evade that result by relying on a “neutral” rule that affected both state and federal damages claims against corrections officers was improper because established precedent precludes a finding of neutrality if the state’s only purpose was to employ a jurisdictional rule to avoid application of a locally disfavored federal statute. The court held that was precisely what New York did here – a conclusion made clear by the fact that the state kept intact plaintiffs’ ability to bring Section 1983 claims for damages against, for instance, police officers, and only restricted such claims against corrections officers. The majority held that the law conflicts with Congress’ determination that all persons who violate federal rights while acting under color of state law must be held liable for damages and, therefore, Corrections Law § 24 violated the Supremacy Clause of the U.S. Constitution.
Justice Clarence Thomas dissented, in an opinion joined by Chief Justice John Roberts and Justices Antonin Scalia and Samuel Alito. The dissent argued from the strict constructionist point of view that because Article III of the Constitution gives Congress the duty of designating federal – and not state – jurisdiction, the states are left to consult their own authority over what cases their courts can and cannot hear. On that basis, then, New York had every right to remove the New York Supreme Court’s jurisdiction to hear Section 1983 claims against state correctional officers.
Reprinted with permission from the June 15, 2010 edition of the Legal Intelligencer Blog, 2010 ALM Media Properties, LLC. All rights reserved. Further duplication without permission is prohibited.