Haywood v. Drown
556 U. S. ____ (2009) (2009)
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Rule of Law:
Under the Supremacy Clause, a state cannot strip its courts of general jurisdiction of the power to hear a specific category of federal claims when those courts are otherwise competent to hear analogous federal and state law claims, as such a targeted jurisdictional limitation is not a neutral rule of judicial administration but an impermissible policy-based evasion of federal law.
Facts:
- Keith Haywood was an inmate at New York’s Attica Correctional Facility.
- Haywood was involved in three separate prisoner disciplinary proceedings.
- Haywood also had an altercation with several correction employees.
- Haywood alleged that these correction employees violated his federal civil rights during the disciplinary proceedings and the altercation.
Procedural Posture:
- Haywood filed two § 1983 lawsuits against correction employees in New York State Supreme Court, which is a trial court of general jurisdiction.
- The trial court dismissed Haywood's actions for lack of jurisdiction pursuant to N.Y. Correction Law § 24.
- The Appellate Division of the Supreme Court, an intermediate appellate court, summarily affirmed the trial court's dismissal.
- The New York Court of Appeals, the state's highest court, affirmed the lower courts' decisions.
- The United States Supreme Court granted certiorari to review the judgment of the New York Court of Appeals.
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Issue:
Does a state law that divests its courts of general jurisdiction over federal § 1983 damages claims against a specific class of state employees (correction officers) violate the Supremacy Clause, even if the law also bars similar state-law claims?
Opinions:
Majority - Justice Stevens
Yes. A state cannot selectively withdraw jurisdiction from its courts over a disfavored federal claim, even if it also withdraws jurisdiction over an identical state claim, because such an action is not a neutral rule of judicial administration but an impermissible policy-based disagreement with federal law. The Supremacy Clause prohibits states from nullifying a federal right or cause of action they believe is inconsistent with local policy. While nondiscrimination between state and federal claims is a necessary condition for a state jurisdictional rule to be valid, it is not sufficient; the rule cannot be used as a device to undermine federal law. New York created courts of general jurisdiction (its Supreme Courts) that hear analogous § 1983 claims against other state officials, and it cannot selectively close the courthouse door to claims against correction officers simply because it views such suits as vexatious. Correction Law § 24 is effectively an immunity statute cloaked in jurisdictional garb, which is unconstitutional under the principles established in Howlett v. Rose.
Dissenting - Justice Thomas
No. New York Correction Law § 24 does not violate the Supremacy Clause because the Constitution does not compel state courts to entertain federal causes of action. The Madisonian Compromise and the structure of Article III leave states with the sovereign authority to determine the subject-matter jurisdiction of their own courts. The Supremacy Clause is a rule of decision that applies only when a court has jurisdiction; it does not confer jurisdiction. Precedent only requires that a state's jurisdictional rules be neutral and not discriminate against federal claims. New York's law is neutral because it divests jurisdiction over both state and federal damages claims against correction officers. Unlike the rule in Howlett, this law is genuinely jurisdictional because a dismissal is without prejudice, allowing the claim to be refiled in federal court, and does not operate as a merits-based immunity defense. The majority's holding improperly expands federal power and forces states into an all-or-nothing choice regarding jurisdiction over federal claims.
Analysis:
This decision significantly clarifies the 'valid excuse' doctrine, establishing that neutrality or non-discrimination is a necessary but not sufficient condition for a state to refuse jurisdiction over a federal claim. The Court asserted its authority to look beyond the 'jurisdictional' label of a state statute to analyze its purpose and effect. By finding that New York's law was an impermissible policy disagreement with § 1983, the Court limited the ability of states to carve out exceptions to their courts' jurisdiction to shield specific state actors from federal liability. This precedent strengthens the enforcement of federal rights in state courts and prevents states from using facially neutral jurisdictional rules to undermine federal law.
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