Haywood v. Drown

Supreme Court of the United States · 2009 · Federal Courts

556 U.S. 729 (2009)

Updated August 1, 2026

Federal Courtsstate jurisdiction-strippingSupremacy Clause§ 1983concurrent state-court jurisdictionsection 1983state courtsconcurrent jurisdiction

Facts

Petitioner, an inmate at Attica Correctional Facility, brought two pro se § 1983 actions in New York Supreme Court against correction employees seeking punitive damages and attorney’s fees for alleged civil-rights violations connected to disciplinary proceedings and an altercation. New York Correction Law § 24 bars damages suits in any state court against correction officers for acts within the scope of employment and instead channels claims to the Court of Claims as claims against the State. In the Court of Claims, plaintiffs face different defendants and reduced remedies and procedures, including a 90-day notice requirement, no jury, no attorney’s fees, and no punitive damages or injunctive relief. New York’s supreme courts otherwise generally exercise jurisdiction over § 1983 suits, including damages actions against other state officials and equitable suits against correction officers.

Issue

Whether New York Correction Law § 24, which divests New York’s trial courts of general jurisdiction over § 1983 suits seeking money damages from correction officers acting within the scope of employment, violates the Supremacy Clause. More specifically, the question is whether New York may selectively withdraw jurisdiction over that narrow category of federal claims while its courts otherwise hear analogous § 1983 actions.

Rule

State courts are presumptively competent to adjudicate federal claims unless Congress expressly ousts state jurisdiction or the state refuses jurisdiction pursuant to a neutral rule regarding the administration of the courts. But a rule is a valid excuse only if it is genuinely neutral: equality of treatment between state and federal claims is necessary but not sufficient, and a State may not employ a jurisdictional rule as a device to undermine federal law or to shield a favored class of defendants from liability that Congress has imposed. When a State has created courts of general jurisdiction that regularly hear analogous suits, it may not close those courts to a disfavored category of federal claims because of disagreement with federal policy.

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One of 10 multiple-choice questions for this case. Pick an answer to see why.

Ohio's trial courts of general jurisdiction routinely hear 42 U.S.C. § 1983 damages suits against city police, county deputies, and state hospital staff. A new Ohio statute provides that § 1983 damages suits against state juvenile-detention officers acting within the scope of employment may not be filed in those courts and instead must be brought as claims against the State in a specialized claims court that offers no punitive damages or attorney's fees.

If Maya Ortiz files a § 1983 damages action in Columbus state trial court against two juvenile-detention officers, what is the strongest argument that the statute violates the Supremacy Clause?

Explanation. The majority held that state courts are presumptively competent to hear federal claims unless Congress ousts jurisdiction or the State relies on a genuinely neutral rule of judicial administration. A rule is not neutral merely because it treats similar state and federal claims equally. Where the State has courts of general jurisdiction that regularly hear analogous § 1983 suits, it may not selectively shut those courts to a disfavored subset of § 1983 damages actions in order to shield a particular class of defendants.