Patsy v. Board of Regents of the State of Florida

Supreme Court of the United States · 1982 · Federal Courts

Federal CourtsSection 1983Exhaustion of Administrative Remedies§ 1983exhaustionstate administrative remediesfederal courtslegislative history

Facts

Georgia Patsy alleged that although she was well qualified and had received uniformly excellent performance evaluations, Florida International University rejected her for more than 13 positions. She claimed the university intentionally filled positions through discrimination on the basis of race and sex. She sought declaratory and injunctive relief or, alternatively, damages. The District Court dismissed because she had not exhausted available state administrative remedies.

Issue

Whether exhaustion of state administrative remedies is a prerequisite to bringing an action under 42 U.S.C. § 1983. More specifically, the question was whether the Court should adopt the Fifth Circuit's flexible exhaustion rule for § 1983 plaintiffs.

Rule

Exhaustion of state administrative remedies is not required as a prerequisite to bringing an action under 42 U.S.C. § 1983. Courts should not defer the exercise of jurisdiction under a federal statute unless doing so is consistent with congressional intent, and Congress has not imposed such a general exhaustion requirement for § 1983 actions.

🔒

See the holding & full analysis

Create a free KwikCourt account to unlock the rest of this brief — and practice the case.

The court's holding and reasoning
Doctrine tests, pitfalls & exam hypotheticals
10 practice questions + 4 AI-graded essays on this case

Free sample · practice this case

Test yourself

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

Nina Patel, a city engineer in Columbus, Ohio, alleges that the municipal public works department denied her promotion because of her national origin and sex. Without using Ohio's civil service appeal board, she files a § 1983 action in federal court seeking damages and an injunction.

How should the federal court rule on the city's motion to dismiss for failure to exhaust the state administrative appeal process?

Explanation. The governing rule is categorical: a plaintiff bringing a § 1983 action need not exhaust state administrative remedies before filing in federal court. The Court rejected requiring exhaustion even where state procedures exist and might address the claim. That rule applies here regardless of whether Nina seeks damages, equitable relief, or both. (Derived from Patsy v. Board of Regents of the State of Florida (1982).)