Haywood v. Drown
United States Supreme Court
556 U.S. 729 (2009)
Keith Haywood (plaintiff), a New York prison inmate proceeding without a lawyer, sued corrections officers, including Curtis Drown (defendant), under 42 U.S.C. §1983 in New York state court, seeking punitive damages and attorney's fees. New York's Correction Law §24 required that such claims against corrections officers be brought instead in the state's court of claims, where plaintiffs face strict procedural requirements and cannot get a jury trial, attorney's fees, punitive damages, or injunctive relief. The state courts dismissed Haywood's claims for lack of jurisdiction, and New York's highest court upheld the law as valid because it treated state-law and federal-law claims against corrections officers the same way. The U.S. Supreme Court granted certiorari to decide whether this equal treatment nonetheless violated the Supremacy Clause.
Whether a state may use a facially neutral jurisdictional rule — one that treats state-law and federal-law claims the same — to prevent its ordinary courts from hearing a disfavored category of §1983 civil rights claims against its own officials.