## Facts

- Joline and Lionel Thiboutot, welfare recipients, alleged Maine officials wrongfully denied benefits under the Aid to Families with Dependent Children program.
- The claim asserted Maine’s administration of eligibility rules conflicted with the federal Social Security Act, including 42 U.S.C. § 602(a)(7).
- The Thiboutots sued state officials in Maine state court under 42 U.S.C. § 1983 for deprivation of rights secured by federal law.
- They sought payment of the allegedly wrongfully withheld benefits and attorney’s fees under 42 U.S.C. § 1988.
- The Maine Superior Court granted relief, and the Maine Supreme Judicial Court held that § 1983 reaches federal statutory violations and that § 1988 permits attorney’s fees in such actions.
- The Supreme Court granted review to decide the scope of § 1983 and the availability of § 1988 fees for statutory § 1983 claims brought in state court.

## Issues

1. Whether 42 U.S.C. § 1983 authorizes an action for deprivation of rights secured by federal statutes, not only constitutional rights.
2. Whether a prevailing plaintiff in a statutory § 1983 action may recover attorney’s fees under 42 U.S.C. § 1988, including when the action is filed in state court.

## Decision

- The Supreme Court affirmed.
- The Court held that § 1983 encompasses claims based on violations of federal statutes because the text covers rights secured by the “Constitution and laws.”
- The Court held that § 1988 authorizes reasonable attorney’s fees in actions enforcing § 1983 without excluding statutory § 1983 claims.
- The Court held that § 1988 attorney’s fees are available in state-court § 1983 actions.
- The Court noted that the Eleventh Amendment does not bar such relief in state court because it limits federal judicial power.

## Legal Principles

- Section 1983 provides a cause of action for deprivations, under color of state law, of rights secured by federal statutes as well as by the Constitution.
- The phrase “and laws” in § 1983 is read according to its ordinary meaning and is not limited to a subset of federal enactments absent statutory limitation.
- Section 1988 permits attorney’s fees to prevailing parties “in any action” to enforce § 1983, including when the underlying § 1983 claim rests on federal statutory rights.
- State courts must apply federally supplied remedies attached to federal rights, including § 1988 fee shifting in § 1983 actions.

## Conclusion

The Court held that § 1983 authorizes suits against state officials for violations of rights created by federal statutes and that prevailing plaintiffs may recover attorney’s fees under § 1988 in such § 1983 actions, whether brought in state or federal court.


Maine v. Thiboutot, 448 U.S. 1 (1980)