Haywood_v_Drown_edited_version - SUPREME COURT OF THE...

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Unformatted text preview: SUPREME COURT OF THE UNITED STATES KEITH HAYWOOD, PETITIONER v. CURTIS DROWN et al. ON WRIT OF CERTIORARI TO THE COURT OF APPEALS OFNEW YORK [May 26, 2009] J USTICE S TEVENS delivered the opinion of the Court. In our federal system of government, state as well as federal courts have jurisdiction over suits brought pursuant to 42 U. S. C. §1983 , the statute that creates a remedy for violations of federal rights committed by persons acting under color of state law. 1 While that rule is generally applicable to New York’s supreme courts—the State’s trial courts of general jurisdiction—New York’s Correction Law §24 divests those courts of jurisdiction over §1983 suits that seek money damages from correction officers. New York thus prohibits the trial courts that generally exercise jurisdiction over §1983 suits brought against other state officials from hearing virtually all such suits brought against state correction officers. The question presented is whether that exceptional treatment of a limited category of §1983 claims is consistent with the Supremacy Clause of the United States Constitution. 2 I Petitioner, an inmate in New York’s Attica Correctional Facility, commenced two §1983 actions against several correction employees alleging that they violated his civil rights in connection with three prisoner disciplinary proceedings and an altercation. Proceeding pro se , petitioner filed his claims in State Supreme Court and sought punitive damages and attorney’s fees. The trial court dismissed the actions on the ground that, under N. Y. Correct. Law Ann. §24 (West 1987) (hereinafter Correction Law §24), it lacked jurisdiction to entertain any suit arising under state or federal law seeking money damages from correction officers for actions taken in the scope of their employment. The intermediate appellate court summarily affirmed the trial court. 35 App. Div. 3d 1290, 826 N. Y. S. 2d 542 (2006). The New York Court of Appeals, by a 4-to-3 vote, also affirmed the dismissal of petitioner’s damages action. The Court of Appeals rejected petitioner’s argument that Correction Law §24’s jurisdictional limitation interfered with §1983 and therefore ran afoul of the Supremacy Clause of the United States Constitution. The majority reasoned that, because Correction Law §24 treats state and federal damages actions against correction officers equally (that is, neither can be brought in New York courts), the statute should be properly characterized as a “neutral state rule regarding the administration...
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This note was uploaded on 11/15/2011 for the course CJ 471 taught by Professor Christophersmith during the Fall '10 term at Michigan State University.

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Haywood_v_Drown_edited_version - SUPREME COURT OF THE...

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