## Facts

- Georgia Patsy worked at Florida International University, a public institution overseen by the Board of Regents of the State of Florida.
- Patsy alleged she was denied multiple employment opportunities because of race and sex discrimination.
- She asserted that she was qualified for numerous positions and had strong performance evaluations but was repeatedly rejected.
- Patsy filed a federal civil rights action under 42 U.S.C. § 1983 seeking declaratory and injunctive relief and damages.
- The Board of Regents argued that Patsy was required to pursue available state administrative discrimination procedures before suing under § 1983.

## Issues

1. Whether a plaintiff must exhaust available state administrative remedies as a prerequisite to filing an action under 42 U.S.C. § 1983.
2. Whether federal courts may impose a general, judge-made exhaustion requirement for § 1983 claims based on policy considerations such as comity, record development, or docket management.

## Decision

- The Supreme Court reversed and remanded.
- The Court held that exhaustion of state administrative remedies is not a prerequisite to an action under 42 U.S.C. § 1983.
- The Court rejected the Fifth Circuit’s conditional exhaustion approach that would require exhaustion in some circumstances.
- The Court relied on the history of § 1983, its prior precedent rejecting administrative exhaustion requirements, and Congress’s decision to create only limited, express exhaustion rules in other statutes.
- The Court concluded that policy arguments supporting exhaustion cannot justify imposing an exhaustion requirement that Congress did not enact and that designing such a regime would generate collateral litigation and delay relief.

## Legal Principles

- Absent an explicit statutory directive from Congress, a § 1983 plaintiff may proceed directly to court without first exhausting state administrative remedies.
- The Court has consistently treated § 1983 as a federal judicial remedy that does not depend on completion of state administrative processes.
- Congress’s creation of a limited exhaustion requirement in specific contexts (such as certain prisoner suits under 42 U.S.C. § 1997e) supports the inference that broader exhaustion requirements should not be judicially added to § 1983.
- Courts should not substitute policy preferences for congressional choices by creating an across-the-board exhaustion doctrine for diverse constitutional and statutory claims against many state agencies.
- A judge-made exhaustion requirement risks delaying remedies and producing threshold litigation about the scope, timing, and adequacy of state administrative procedures rather than resolving the merits of the civil rights claim.

## Conclusion

The Court held that § 1983 does not generally require plaintiffs to exhaust state administrative remedies before suing, reaffirming that any exhaustion obligation must come from Congress rather than judicial policy-making and preserving prompt access to federal courts for civil rights claims.


Patsy v. Bd. of Regents of State of Fla., 457 U.S. 496 (1982)