## Facts

- Keith Haywood, a New York state prisoner, was found guilty in prison disciplinary proceedings in 2003 and 2004 for several rule violations.
- Haywood filed two pro se civil-rights suits in New York Supreme Court seeking money damages (including punitive damages) and attorney’s fees under 42 U.S.C. § 1983 against individual correction employees, including hearing officer Curtis Drown.
- New York Correction Law § 24 required damages claims against correction officers for acts within the scope of employment to be brought only against the State in the New York Court of Claims.
- The state trial court dismissed Haywood’s § 1983 suits for lack of jurisdiction under § 24; intermediate appellate review affirmed.
- The New York Court of Appeals affirmed, characterizing § 24 as a neutral jurisdictional rule applicable to both state-law and federal damages claims against correction officers.
- Channeling claims to the Court of Claims eliminated certain remedies available in § 1983 actions against individuals, including jury trials, punitive damages, injunctive relief, and attorney’s fees under 42 U.S.C. § 1988.
- The U.S. Supreme Court granted review to decide whether § 24’s jurisdictional bar, as applied to § 1983 claims, violated the Supremacy Clause.

## Issues

1. Whether a State may withdraw its courts of general jurisdiction from hearing § 1983 damages actions against state correction officers acting within the scope of employment by forcing such claims into a Court of Claims action against the State.
2. Whether such a jurisdictional withdrawal is a permissible neutral rule of judicial administration or an impermissible state-law obstacle to Congress’s remedial scheme for enforcing federal rights under § 1983.

## Decision

- The Supreme Court reversed and remanded.
- The Court held that New York Correction Law § 24, as applied to § 1983 claims, violates the Supremacy Clause.
- The Court rejected the view that § 24 was a neutral jurisdictional rule because it functionally displaced Congress’s choice to allow damages actions against state officers in their personal capacities.
- The Court concluded that channeling these cases exclusively to a suit against the State in the Court of Claims materially diminished the federal remedial scheme Congress created for constitutional violations committed under color of state law.
- A dissent would have upheld § 24 as a permissible state allocation of jurisdiction that did not discriminate against federal claims relative to analogous state-law claims.

## Legal Principles

- State courts of general jurisdiction are presumed competent to adjudicate federal causes of action, including § 1983 claims, absent congressional exclusivity or a genuinely neutral state rule governing court administration.
- A State may apply neutral rules of judicial administration that do not discriminate against, or operate to defeat, federal rights.
- Under the Supremacy Clause, a State may not close its courts to a federal cause of action based on disagreement with Congress’s policy choice or to avoid the consequences of the federal remedy.
- A state jurisdictional rule is invalid if, in operation, it stands as an obstacle to accomplishing Congress’s objectives for a federal right, including Congress’s decision to allow damages actions against individual state officials under § 1983 and to make related federal remedies available.

## Conclusion

The Court held that New York’s statutory removal of state-court jurisdiction over § 1983 damages suits against correction officers, coupled with mandatory substitution of a Court of Claims action against the State, conflicted with Congress’s enforcement design for federal civil-rights claims and was therefore preempted by the Supremacy Clause.


Haywood v. Drown, 556 U.S. 729 (2009)