Labor & Employment Law

Correction officers may be sued by prisoners seeking money damages for alleged violations of 42 USC §1983 rights in state supreme court

Correction officers may be sued by prisoners seeking money damages for alleged violations of 42 USC §1983 rights in state supreme court

Haywood v Drown et al, Certiorari to the Court of Appeals of New York, USSC No. 07?10374.Decided May 26, 2009

New York's Correction Law §24 provides that New York State's trial courts of general jurisdiction cannot entertain §1983 suits filed by prison inmates seeking money damages from correction officers.

The question before the U.S. Supreme Court: is this ?exceptional treatment of a limited category of §1983 claims? consistent with the Supremacy Clause of the United States Constitution?^*

This case arose when Corrections Department inmate Keith Heywood two actions filed in New York State Supreme Court pursuant to 42 USC §1983 against several correction employees alleging that they violated his civil rights in connection with three prisoner disciplinary proceedings and an altercation were dismissed ?for lack of jurisdiction.?

Ultimately New York?s Court of Appeals upheld lower court rulings, holding that §24 of the State?s Corrections Law deprived New York?s trial courts of ?jurisdiction to entertain any suit arising under state or federal law seeking money damages from correction officers for actions taken in the scope of their employment.? [35 App. Div. 3d 1290, 9 N. Y. 3d 481].

This meant that a prisoner seeking damages from a correction officer would have to pursue his or her claim for damages against an entirely different party, the State, rather than the correction officer, in a different judicial forum, the Court of Claims.

A majority of the Supreme Court Justices** reverse, holding that Correction Law §24 violates the Federal Constitution?s Supremacy Clause.

The majority held:

1. Although the absence of discrimination is necessary to our finding a state law neutral, it is not sufficient;

2. A jurisdictional rule cannot be used as a device to undermine federal law, no matter how evenhanded it may appear; and

3. That a rule is denominated jurisdictional does not provide a court an excuse to avoid the obligation to enforce federal law if the rule does not reflect the concerns of power over the person and competence over the subject matter that jurisdictional rules are designed to protect.

The court pointed out that if Haywood had attempted to sue a police officer for damages under §1983, the suit would be properly adjudicated by a state supreme court. Similarly, if Haywood had sought declaratory or injunctive relief against a correction officer, that suit would be heard in a state supreme court. It is only a particular species of suits said the Supreme Court -- those seeking damages relief against correction officers -- that the State deems inappropriate for its trial courts.

The majority then ruled that ?having made the decision to create courts of general jurisdiction that regularly sit to entertain analogous suits, New York is not at liberty to shut the courthouse door to federal claims that it considers at odds with its local policy.?

* The Supremacy Clause, Article VI, Clause 2, provides: "This Constitution, and the Laws of the United States which shall be made in Pursuance thereof; and all Treaties made, or which shall be made, under the Authority of the United States, shall be the supreme Law of the Land; and the Judges in every State shall be bound thereby, any Thing in the Constitution or Laws of any State to the Contrary notwithstanding."

** Justice Thomas, with whom The Chief Justice, Justice Scalia, and Justice Alito join as to Part III of the minority decision, dissented.

The majority and minority Supreme Court decisions are posted on the Internet at:

http://www.supremecourtus.gov/opinions/08pdf/07-10374.pdf

Full post as published by New York Public Personnel Law on May 27, 2009 (boomark / email).