Haywood v. Drown

PETITIONER: Keith Haywood
RESPONDENT: Curtis Drown, et al.
LOCATION: Attica Correctional Facility

DOCKET NO.: 07-10374
DECIDED BY: Roberts Court (2006-2009)
LOWER COURT: New York Court of Appeals

CITATION: 556 US (2009)
GRANTED: Jun 16, 2008
ARGUED: Dec 03, 2008
DECIDED: May 26, 2009

ADVOCATES:
Barbara D. Underwood - argued the cause for the respondent
Jason E. Murtagh - argued the cause for the petitioner

Facts of the case

Keith Haywood, while incarcerated at the Attica Correctional Facility in Attica, New York, was charged with several misbehavior reports in 2003 and 2004, including assaulting a corrections officer, failing a urinalysis test, and improperly soliciting mail. After being found guilty of these charges, Haywood commenced actions in state court against two of the corrections officers responsible for reviewing the claims under 42 U.S.C. 1983 (Section 1983), a federal statute protecting civil rights. He asserted that the guilty verdicts had been handed down without sufficient evidence, that the officers had tampered with the urinalysis test, and that they had conspired to fabricate the facts set forth in the misbehavior reports. The defendants moved to dismiss Haywood's claims, basing their argument on a New York law prohibiting civil claims such as Haywood's brought against corrections officers in their official capacities. Haywood responded by arguing that when Congress created Section 1983 it intended the statute to supersede any state laws contradicting it. Because Section 1983 allowed these claims, Haywood argued, the New York law prohibiting them violated the Supremacy Clause of the U.S. Constitution. The Supreme Court of New York (the state's lowest-level court) agreed with the defendants and dismissed Haywood's claim based on the New York law.

The Court of Appeals of New York affirmed the Supreme Court's decision, finding that the Supremacy Clause permits states to deny enforcement of a federal right in a case where a state court lacks jurisdiction due to a neutral state rule regarding the courts' administration. Because Haywood's claim would be barred if brought under either Section 1983 or an applicable state law, the New York law barring the claim was valid and neutral and did not violate the Supremacy Clause.

Question

Does a state law barring civil claims against corrections officers violate the Supremacy Clause of the United States Constitution when it prohibits an inmate from bringing a claim for a violation of his civil rights under 42 U.S.C. 1983?

Media for Haywood v. Drown

Audio Transcription for Oral Argument - December 03, 2008 in Haywood v. Drown

Audio Transcription for Opinion Announcement - May 26, 2009 in Haywood v. Drown

John G. Roberts, Jr.:

Justice Stevens also has our opinion this morning in the case 07-10374, Haywood versus Drown.

John Paul Stevens:

This case comes to us from the state court for the Court of Appeals of New York.

Petitioner, a prison inmate filed two 1983 actions against several correction officials alleging that they violated his civil rights.

He filed his claims in the State Supreme Court which is the trial court in New York and sought punitive damages and attorney's fees.

The trial court dismissed the action on the ground that under New York's Correction Law Section 24, it lacked jurisdiction to entertain any suit, federal or state seeking money damages from correction officers.

On appeal, petitioner argued that Correction Law Section 24 has jurisdiction limitation interfered with Section 1983 and therefore violated the Supremacy Clause of the United States Constitution.

The New York Court of Appeals disagreed.

It held that because the law treats federal and state damage actions against correction officials equally, it should be considered a valid excuse for the State's refusal to entertain petitioner's federal cause of action.

We granted certiorari and now reverse.

For reasons stated in an opinion filed with the clerk, we hold that the Correction Law violates the Supremacy Clause.

The law is motivated by New York's belief that damages suits filed by prisoners against correction officers are by and large frivolous and that the state actor should be shielded from liability.

The fact that New York has chosen to effectuate this policy goal by selectively withdrawing jurisdiction from its courts overall such to suits, federal and state does not alter our Supremacy Clause analysis.

Justice Thomas has filed a dissenting opinion.

The Chief Justice, Justice Scalia, and Justice Alito have joined Part III of that opinion.