Felder v. Casey

PETITIONER: Felder
RESPONDENT: Casey
LOCATION: Pima County Jail

DOCKET NO.: 87-526
DECIDED BY: Rehnquist Court (1988-1990)
LOWER COURT:

CITATION: 487 US 131 (1988)
ARGUED: Mar 28, 1988
DECIDED: Jun 22, 1988

Facts of the case

Question

Media for Felder v. Casey

Audio Transcription for Oral Argument - March 28, 1988 in Felder v. Casey

Audio Transcription for Opinion Announcement - June 22, 1988 in Felder v. Casey

William H. Rehnquist:

The opinion of the Court in No. 87-526, Felder against Casey will be announced by Justice Brennan.

William J. Brennan, Jr.:

This -- this case is here on certiorari to the Supreme Court of Wisconsin.

Nine months after being allegedly beaten by Milwaukee police officers who arrested petitioner on a disorderly conduct charge that was later dropped.

Petitioner filed in a Wisconsin state court, this action under the federal statute 42 U.S.C. 1983.

The complaint alleged that the beating and arrest were racially motivated, and violated the plaintiff's rights under the Fourth and Fourteenth Amendments to the Federal Constitution.

Now, Wisconsin has a notice of claim statute, which provides among other things that before a suit like this may be brought in a state court against a state or local governmental entity or officer, the plaintiff, within 120 days of the alleged injury, must notify the defendant of the circumstances and amount of the claim and the plaintiff's intent to hold the named defendant or defendants liable.

The defendant, after filing that notice, then has 120 days to grant or disallow the requested relief.

If the defendant denies the relief, the plaintiff must bring suit within six months of receiving the notice of disallowance.

The trial court denied a motion of the respondents to dismiss the suit as to petitioner's 1983 claim for failure to comply with the statute, and the Wisconsin intermediate Court of Appeals affirmed.

The Wisconsin Supreme Court, however, reversed holding that while Congress may establish the procedural framework under which claims are heard in federal courts, states retain the authority under the Constitution to prescribe procedures that govern actions in their own tribunals including actions to vindicate congressionally created rights such as the rights created by 1983.

We reversed the Wisconsin Supreme Court.

We hold that because Wisconsin notice of claim statute conflicts both in its purpose and the fact with 1983's remedial objectives, and because its enforcement in state-court actions will frequently and predictably produce different outcomes in 1983 litigation based solely on whether the claim is asserted in state or a federal court, the notice of claim statute is pre-empted pursuant to the Supremacy Clause when the 1983 action is brought in a state court.

Wisconsin's notice of claim statute, we think undermines 1983's unique remedy against state governmental bodies and their officials by conditioning the right of recovery so as to minimize governmental liability.

The state statute also discriminates against the federal right against the state of -- affords the victim of an intentional tort two years to recognize the compensable nature of his or her injury while the civil rights victim is given only four months to appreciate that he or she has been deprived of a federal constitutional or statutory right.

Moreover, the notice provision operates in part as an exhaustion requirement by forcing claimants to seek satisfaction in the first instance from the governmental defendant.

Congress, we think, never intended that those injured by governmental wrongdoers could be required, as a condition of recovery, to submit their claims to the government responsible for their injuries.

Finally, application of Wisconsin's statute to state-court 1983 actions cannot be approved as a matter of equitable federalism.

Just as federal courts are constitutionally obligated to apply state law to state claims, the Supremacy Clause imposes on state courts a constitutional duty to proceed in such manner that all the substantial rights of the parties under controlling federal law are protected.

A state law that predictably alters the outcome of 1983 claims depending solely on whether they are bought in a state or federal court within the State is obviously inconsistent with the federal interest, 1983 was enacted by the Congress to further.

Justice White has filed a concurring opinion.

Justice O'Connor has filed a dissenting opinion in which the Chief Justice has joined.