May 26, 2009

Supreme Court Decides Haywood v. Drown

On May 26, the Supreme Court decided Haywood v. Drown, 07-10374.

The state of New York enacted a statute that divested its state courts of jurisdiction over civil rights lawsuits against state correction officers, whether those lawsuits arose under federal law (including 42 U.S.C. § 1983) or state law. New York courts could continue to entertain federal law and state law claims against other categories of defendants.

A 5–4 majority held that New York's law violated the Supremacy Clause of the Constitution. While states have the right to refuse jurisdiction over cases (including those arising under federal law) because of a neutral state rule regarding the administration of the courts, they may not bar lawsuits arising under federal law because the state's policy stands against such lawsuits. The Supreme Court held that New York's law was based on the judgment that correction officers should not be burdened with suits for damages arising out of the scope of their employment. That policy is contrary to Congress' judgment—expressed through § 1983—that anyone who violates federal rights while acting under color of state law shall be held liable for damages.

New York defended its law on the ground that it did not discriminate against federal law because the jurisdictional bar applies to state law claims as well as federal law claims. The Court held that nondiscrimination against federal law is necessary for a law to comply with the Supremacy Clause, but not sufficient to do so. Even though New York's jurisdiction-divesting law does not discriminate against federal law, it still impedes the application of federal law in state court because of the state's belief that a certain category of claims should be disfavored.

Justice Stevens delivered the opinion for the majority. Justice Thomas filed a dissenting opinion in which Chief Justice Roberts and Justices Scalia and Alito joined.

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