Wednesday, May 27, 2009
A sharply divided Supreme Court ruled yesterday that New York's efforts to limit prisoners' federal civil rights claims in New York state courts violated the Supremacy Clause.
New York moved to restrict prisoner-rights claims in New York state courts under 42 U.S.C. Sec. 1983 in order to curb what it deemed "frivolous and vexatious" suits against state correctional officers. (Section 1983, a Reconstruction-era statute, authorizes civil suits against state officers for violations of federal constitutional rights in the scope of their employment. Plaintiffs can file in federal courts or in state courts of general jurisdiction.) Thus the state stripped its courts of jurisdiction over Section 1983 claims by prisoners against correction officers. (The state also stripped its courts of jurisdiction under a state statute that, like Section 1983, authorized civil suits against state officers for violations of constitutional rights.) But the state granted jurisdiction over these claims to a state court of limited jurisdiction, the Court of Claims, with a 90-day notice requirement, no entitlement to a jury trial, no right to attorney's fees, and no punitive damages or injunctive relief.
The New York law thus severely restricted prisoner-rights claims in state courts under Section 1983. (Prisoners, of course, could still file a Section 1983 claim in federal court.)
Justice Stevens (for himself and Justices Kennedy, Souter, Ginsburg, and Breyer) ruled that the New York law violated the Supremacy Clause. Stevens wrote that while "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." Slip Op. at 6. Because New York's law "operates more as an immunity-from-damages provision than as a jurisdictional rule," Slip Op. at 7, n. 5, it's not a "neutral state rule regarding the administration of the courts"--an exception to the "presumption of concurrency" between federal and state law under Howlett v. Rose (1990). Slip Op. at 6.
Moreover, the law was not "neutral," even though it divested state courts of jurisdiction over both state and federal law authorizing prisoner constitutional rights suits, because it targeted only a "particular species of suits--those seeking damages relief against correction officers." Slip Op. at 10. Stevens for the Court:
We therefore hold that, having made the decision to create courts of general jurisdiction that regularly sit to entertain analogous suits, New York is not at liberty to shut the courthouse door to federal claims that it considers at odds with its local policy. A State's authority to organize its courts, while considerable, remains subject to the strictures of the Constitution.
Slip Op. at 11.
In dissent, Justice Thomas (for himself, Chief Justice Roberts, and Justices Scalia and Alito) argued that the Court's cases didn't support the non-discriminatory requirement in the Court's definition of "neutral" and that states had plenty of authority and room to issue neutral rules of administration for their own courts. (Roberts, Scalia, and Alito joined only a narrow part of Thomas's much broader opinion, part of which focused on the original intent of Article III.)
The case is a victory for federal civil rights claimants in state courts. It means that states that seek to limit access to their courts for federal constitutional rights claimants face a higher bar--one that New York's efforts failed to satisfy--and that states can't try to side-step their way around federal civil rights law by disguising an immunity provision as a jurisdictional rule, even as states retain substantial authority to organize their own courts.