Maine v. Thiboutot
448 U.S. 1 (1980)
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Rule of Law:
The cause of action provided by 42 U.S.C. § 1983 for the deprivation of rights secured by the 'laws' of the United States is not limited to civil rights or equal protection laws, but encompasses claims based on violations of purely federal statutory law. Prevailing parties in such actions, whether brought in state or federal court, are eligible for an award of attorney's fees under 42 U.S.C. § 1988.
Facts:
- Lionel and Joline Thiboutot, a married couple with eight children, received Aid to Families with Dependent Children (AFDC) benefits in Maine.
- Three of the eight children were from Lionel's previous marriage.
- The Maine Department of Human Services notified Lionel Thiboutot that it was changing its method for calculating AFDC benefits.
- Under the new method, in computing benefits for Lionel's three children, the Department would no longer make an allowance for the money he spent to support the other five children, despite his legal obligation to do so.
- This change in calculation resulted in a reduction of the family's total welfare benefits.
- The Thiboutots contended that this new state policy violated the federal Social Security Act, specifically 42 U.S.C. § 602(a)(7).
Procedural Posture:
- The Thiboutots exhausted their state administrative remedies regarding their welfare benefits.
- They sought judicial review in the Maine Superior Court, a state trial court.
- In an amended complaint, the Thiboutots added a claim for relief under 42 U.S.C. § 1983 for themselves and as class representatives.
- The Superior Court ruled in favor of the Thiboutots on the merits of their claim but denied their motion for attorney's fees.
- The Thiboutots appealed the denial of attorney's fees to the Supreme Judicial Court of Maine, the state's highest court.
- The Supreme Judicial Court of Maine reversed, holding that the Thiboutots were eligible for attorney's fees under the federal Civil Rights Attorney’s Fees Awards Act of 1976 (42 U.S.C. § 1988).
- The State of Maine and its Commissioner (as petitioners) successfully petitioned the U.S. Supreme Court for a writ of certiorari.
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Issue:
Does 42 U.S.C. § 1983, which protects rights secured by the Constitution 'and laws,' authorize a lawsuit against state officials for violating a purely federal statute, and if so, does 42 U.S.C. § 1988 permit an award of attorney's fees for such a claim brought in state court?
Opinions:
Majority - Mr. Justice Brennan
Yes, 42 U.S.C. § 1983 authorizes a lawsuit for purely statutory violations, and 42 U.S.C. § 1988 permits an award of attorney's fees for such claims. The plain language of § 1983's phrase 'and laws' is unambiguous and is not modified, thus it encompasses all federal laws, not just civil rights statutes. This interpretation is supported by a consistent line of Supreme Court cases that have, implicitly or explicitly, allowed § 1983 actions to enforce the Social Security Act. The legislative history of the 1874 revision that added the phrase 'and laws' is inconclusive and does not provide a definitive reason to depart from the statute's plain meaning. Similarly, the plain text of § 1988 allows for attorney's fees in 'any action' to enforce § 1983, making no exception for purely statutory claims. Legislative history confirms that Congress anticipated the Fees Act would apply to such cases, and the Supremacy Clause requires that this federal remedy be available in state courts as well.
Dissenting - Mr. Justice Powell
No, § 1983 should not be interpreted to create a cause of action for every federal statutory right, and attorney's fees under § 1988 should therefore not be available. The majority's reliance on the 'plain meaning' of 'and laws' ignores the historical context of the 1874 statutory revision, which strongly suggests Congress had no intention of making substantive changes and that the phrase was merely a shorthand for federal laws providing for equal rights. The Court's decision creates an illogical inconsistency between § 1983 and its jurisdictional counterpart, 28 U.S.C. § 1343(3), which is limited to equal rights statutes. This ruling dramatically and improperly expands the liability of state officials, authorizing a flood of litigation over the administration of hundreds of federal-state cooperative programs that are unrelated to civil rights. The precedents cited by the majority are unpersuasive, as they either decided the issue sub silentio or relied on unexamined dicta.
Analysis:
This is a landmark decision that significantly broadened the scope of § 1983 litigation. By holding that the phrase 'and laws' encompasses all federal statutes, the Court transformed § 1983 from a remedy primarily for constitutional and civil rights violations into a general cause of action for any state-inflicted deprivation of a federally-secured statutory right. This opened the door for lawsuits against state and local governments concerning the administration of a vast array of federal programs, such as welfare, housing, and environmental regulations. The holding that § 1988 attorney's fees are available for these statutory claims created a powerful incentive for plaintiffs to bring such suits, fundamentally altering the landscape of federal-state relations and judicial oversight of state-administered federal programs.
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