Haywood v. Drown (2008)
- Docket
- 07-10374
- Decided
- 2008-01-01
Summary
Question: Does a state law barring civil claims against corrections officers violate the Supremacy Clause of the United States Constitution when it prohibits an inmate from bringing a claim for a violation of his civil rights under 42 U.S.C. 1983? Conclusion: Yes. The Supreme Court held that New York's Correction Law Section 24, prohibiting civil claims brought against corrections officers in their official capacities, as applied in Mr. Haywood's case, violated the Supremacy Clause and thus was unconstitutional. With Justice John Paul Stevens writing for the majority and joined by Justices Anthony M. Kennedy, David H. Souter, Ruth Bader Ginsburg, and Stephen G. Breyer, the Court noted that New York had passed Section 24 after determining most damages suits filed by prisoners against state corrections officers were frivolous. However, the Court reasoned that states may not relieve whole categories of federal claims from their courts merely to avoid congestion. Justice Clarence Thomas dissented and was joined in part by Chief Justice John G. Roberts, and Justices Antonin G. Scalia, and Samuel A. Alito. He argued that neither the Constitution nor Supreme Court precedent requires that states open their courts to Section 1983 claims. Thus, New York's law was not unconstitutional.