by Brandon Sample
New York’s Correction Law § 24, which prevents prisoners from bringing 42 U.S.C. § 1983 actions for damages against prison officials in New York courts of general jurisdiction, violates the Supremacy Clause of the U.S. Constitution, the U.S. Supreme Court decided on May 26, 2009.
Believing that most damages suits filed by prisoners against prison officials were frivolous or vexatious, New York enacted Correction Law § 24. The law, passed in the 1980s, strips New York’s courts of general jurisdiction from hearing damages actions brought by prisoners against prison officials. Instead, all such claims must be presented in New York’s Court of Claims, with the state being substituted as the party defendant.
However, there are several disadvantages to bringing damages suits in the Court of Claims. For example, plaintiffs have no right to a jury trial, no right to attorney’s fees, and may not seek punitive damages or injunctive relief. New York’s courts of general jurisdiction, all of which routinely hear § 1983 actions against non-prison defendants, are not subject to any of these restrictions.
Keith Haywood, a prisoner at New York’s Attica Correctional Facility, filed a § 1983 action against several prison officials alleging that his civil rights had been violated in connection with three prison disciplinary proceedings. His complaint, filed in state Supreme Court, sought damages and attorney’s fees.
Invoking Correction Law § 24, the court dismissed Haywood’s suit for lack of jurisdiction, and the New York Court of Appeals – the state’s highest court – affirmed in a 4-3 vote. See: Haywood v. Drown, 2007 NY Slip Op 9308, 1 (N.Y. 2007).
In doing so, the Court of Appeals rejected Haywood’s argument that Correction Law § 24 ran afoul of the Supremacy Clause of the U.S. Constitution because it interfered with § 1983, a federal statute. The Court of Appeals reasoned that because Correction Law § 24 discriminated against both federal and state law damages actions against prison officials equally (in that neither could be brought in state court), the law represented a “neutral rule” regarding court administration and therefore constituted a “valid excuse” for the state to limit § 1983 damages actions against prison officials. The U.S. Supreme Court granted certiorari and reversed.
Section 1983, enacted in the wake of the Civil War during Reconstruction, was designed to allow litigants to seek relief in either state or federal court for violations of federal rights “by state or local officials acting under color of state law.” State jurisdiction to hear § 1983 actions, the Supreme Court wrote, can only be withdrawn by Congress or by a state based on a “neutral rule regarding the administration of the courts.” Congress did not withdraw jurisdiction from New York courts, so the only question was whether Correction Law § 24 was neutral. The Supreme Court concluded that it was not.
“Although states retain substantial leeway to establish the contours of their judicial systems, they lack authority to nullify a federal right or cause of action they believe is inconsistent with their local policies,” the Court explained.
The fact that Correction Law § 24 withdraws jurisdiction for both state and federal claims against prison officials for damages does not make the law “neutral,” the Supreme Court emphasized. “Equality of treatment does not ensure that a state law will be deemed a neutral rule.”
Because other § 1983 suits for damages may be entertained by New York courts of general jurisdiction, “New York is not at liberty to shut the courthouse door to federal claims that it considers at odds with its local policy.” The judgment of the New York Court of Appeals to the contrary was therefore reversed, and the case remanded for further proceedings. See: Haywood v. Drown, 129 S.Ct. 2108 (2009).
PLN supported Haywood’s effort to overturn Correction Law § 24, and joined an amicus (friend of the court) brief filed with the U.S. Supreme Court by Prisoners’ Legal Services of New York. Other organizations that joined in the amicus brief included the Prisoners Rights Project, New York State Defenders Association, Center for Community Alternatives, Uptown People’s Law Center, Legal Services Organization of Yale Law School, and Civil Rights Clinic of New York University School of Law. The pleadings in the case are on PLN’s website.
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Related legal cases
Haywood v. Drown
|Cite||129 S.Ct. 2108 (2009)|
Haywood v. Drown
|Cite||2007 NY Slip Op 9308, 1 (N.Y. 2007)|
|Level||State Court of Appeals|