Haywood v. Drown

Last updated
Haywood v. Drown
Seal of the United States Supreme Court.svg
Argued December 3, 2008
Decided May 26, 2009
Full case nameKeith Haywood, Petitioner v. Curtis Drown, et al.
Docket no. 07-10374
Citations556 U.S. 729 ( more )
129 S. Ct. 2108; 173 L. Ed. 2d 920
Case history
Priordismissal affirmed 9 N.Y.3d 481, 881 N.E.2d 180 (2008), reversed and remanded U.S.
Holding
A state law barring state courts from hearing damages actions against corrections officers violates the Supremacy Clause by not permitting adjudication of claims under 42 USC 1983.
Court membership
Chief Justice
John Roberts
Associate Justices
John P. Stevens  · Antonin Scalia
Anthony Kennedy  · David Souter
Clarence Thomas  · Ruth Bader Ginsburg
Stephen Breyer  · Samuel Alito
Case opinions
MajorityStevens, joined by Kennedy, Souter, Ginsburg, Breyer
DissentThomas, joined by Roberts, Scalia, Alito (Part III)
Laws applied
U.S. Const. art. VI (Supremacy Clause)

Haywood v. Drown, 556 U.S. 729 (2009), was a United States Supreme Court case in which the Court held that a New York law preventing state trial courts from hearing claims for money damages against prison employees whether based on federal or state law violated the Supremacy Clause of the United States Constitution.

Contents

Background

The defendant in this trial, Keith Haywood, was an inmate at the Attica Correctional Facility, in Attica, New York In 2003 and 2004, Haywood was charged with multiple counts of misbehavior, including assaulting an officer, soliciting mail, and failing a drug test. After a guilty verdict, Haywood filed suit in a New York state court against two employees of the Attica Correctional facility to review the claims under 42 U.S.C. § 1983. The defendants moved to dismiss Haywood's claims based on a New York statute that banned inmates from filing suit against the "official capacities" of correctional officers of the state. [1]

Decision of the Supreme Court

Writing for the majority in favor of Haywood, Justice Stevens wrote the opinion of the Supreme Court. The court noted that the New York statute was passed to protect correctional facilities employees against "frivolous" damages suits filed by inmates. The Court found, however, that states "may not relieve whole categories of federal claims from their courts merely to avoid congestion." [1] [2]

Dissenting opinions

In dissent, Justice Clarence Thomas note that "neither the Constitution nor Supreme Court precedent require that states open their courts to Section 1983 claims." [1]

Arguments

The case was argued by Jason E. Murtagh, an attorney with Dechert, for the Petitioner, and by Barbara D. Underwood for Respondent.

See also

Related Research Articles

United States v. X-Citement Video, Inc., 513 U.S. 64 (1994), was a federal criminal prosecution filed in the United States District Court for the Central District of California in Los Angeles against X-Citement Video and its owner, Rubin Gottesman, on three charges of trafficking in child pornography, specifically videos featuring the underaged Traci Lords. In 1989, a federal judge found Gottesman guilty and later sentenced him to one year in jail and a $100,000 fine.

Bivens v. Six Unknown Named Agents, 403 U.S. 388 (1971), was a case in which the US Supreme Court ruled that an implied cause of action existed for an individual whose Fourth Amendment protection against unreasonable search and seizures had been violated by the Federal Bureau of Narcotics. The victim of such a deprivation could sue for the violation of the Fourth Amendment itself despite the lack of any federal statute authorizing such a suit. The existence of a remedy for the violation was implied by the importance of the right violated.

Cort v. Ash, 422 U.S. 66 (1975), was a case in which the United States Supreme Court determined whether a court may imply a cause of action from a criminal statute.

American Well Works Co. v. Layne & Bowler Co., 241 U.S. 257 (1916), was a United States Supreme Court case governing the scope of federal question jurisdiction.

Arkansas Department of Human Services v. Ahlborn, 547 U.S. 268 (2006), was a decision by the Supreme Court of the United States involving the ability of a state agency to claim a personal injury settlement as compensation for Medicaid benefits provided for treatment of the injuries. The Court ruled unanimously that a federal statutory prohibition against liens on personal property to recover Medicaid expenditures applied to settlements, so that only the portion of the settlement that represented payment for past medical expenses could be claimed by the state.

Curtis Publishing Co. v. Butts, 388 U.S. 130 (1967), was a landmark decision of the US Supreme Court establishing the standard of First Amendment protection against defamation claims brought by private individuals.

The Office of the Missouri Attorney General was created in 1806 when Missouri was part of the Louisiana Territory. Missouri's first Constitution in 1820 provided for an appointed attorney general, but since the 1865 Constitution, the Attorney General has been elected. As of January 2023, there have been 44 attorneys general in Missouri.

Correctional Services Corporation v. Malesko, 534 U.S. 61 (2001), was a case decided by the United States Supreme Court, in which the Court found that implied damages actions first recognized in Bivens v. Six Unknown Named Agents should not be extended to allow recovery against a private corporation operating a halfway house under contract with the Bureau of Prisons.

Ziglar v. Abbasi, 582 U.S. ___ (2017), is a Supreme Court of the United States case in which the Court determined, by a vote of 4–2, that non-U.S. citizens detained in the aftermath of the September 11 attacks cannot recover monetary damages from high level federal officials for the conditions of their confinement. The case was consolidated with Hastey v. Abbasi, and Ashcroft v. Abbasi. It was argued on January 18, 2017.

United States ex rel. Eisenstein v. City of New York, 556 U.S. 928 (2009), is a United States Supreme Court decision holding that where the Government has not intervened or actively participated, private plaintiffs under the False Claims Act must file an appeal within 30 days of the judgment or order being appealed, according to the Federal Rules of Appellate Procedure.

United States v. Georgia, 546 U.S. 151 (2006), was a United States Supreme Court case in which the Court decided that the protection of Americans with Disabilities Act of 1990 (ADA), passed by the U.S. Congress, extends to persons held in a state prison and protects prison inmates from discrimination on the basis of disability by prison personnel. Specifically, the court held that Title II of the Americans with Disabilities Act of 1990, 42 U.S.C. §§ 1213112165., is a proper use of Congressional power under the Fourteenth Amendment, Section 5, making it applicable to prison system officials.

Porter v. Nussle, 534 U.S. 516 (2002), is a United States Supreme Court case in which the court settled an intercircuit conflict regarding civil procedure for prisoners seeking redress. The court held that prisoners alleging assaults by prison guards must meet §1997e(a)'s exhaustion requirement before commencing a civil rights action.

Los Angeles County v. Humphries, 562 U.S. 29 (2010), is a decision by the Supreme Court of the United States that clarified one of the requirements for imposing liability on a municipality for violations of a federal right, in lawsuits brought under Section 1983 of the Civil Rights Act of 1871.

American Electric Power Company v. Connecticut, 564 U.S. 410 (2011), was a United States Supreme Court case in which the Court, in an 8–0 decision, held that corporations cannot be sued for greenhouse gas emissions (GHGs) under federal common law, primarily because the Clean Air Act (CAA) delegates the management of carbon dioxide and other GHG emissions to the Environmental Protection Agency (EPA). Brought to court in July 2004 in the Southern District of New York, this was the first global warming case based on a public nuisance claim.

Booth v. Churner, 532 U.S. 731 (2001), was a United States Supreme Court case decided in 2001. The case concerned the extent to which a state prisoner must first utilize an administrative review process provided by the state, prior to filing a case in federal district court. The Court held that Booth still had a mechanism of administrative review, and thus his claim was premature.

<i>Inmates of Attica Correctional Facility v. Rockefeller</i>

Inmates of Attica Correctional Facility v Rockefeller, 477 F.2d 375 (1973) was a United States 2nd Circuit Court of Appeals case that affirmed the right of state prosecutors to choose whether to investigate and prosecute individuals that have potentially committed a crime.

Petrella v. Metro-Goldwyn-Mayer, Inc., 572 U.S. 663 (2014), is a United States Supreme Court copyright decision in which the Court held 6-3 that the equitable defense of laches is not available to copyright defendants in claims for damages.

Jesner v. Arab Bank, PLC, No. 16-499, 584 U.S. ___ (2018), was a case from the United States Supreme Court which addressed the issue of corporate liability under the Alien Tort Statute (ATS). Plaintiffs alleged that Arab Bank facilitated terrorist attacks by transferring funds to terrorist groups in the Middle East, some of which passed through Arab Bank's offices in New York City.

Tanzin v. Tanvir, 592 U.S. ___ (2020), was a United States Supreme Court case involving legal remedies that could be sought by litigants against federal officials for violations of the Religious Freedom Restoration Act of 1993. In a unanimous decision issued December 10, 2020, the court ruled that the Act allowed for litigants to seek not only injunctive relief but also monetary damages.

TransUnion LLC v. Ramirez, 594 U.S. ___ (2021), was a United States Supreme Court case dealing with standing under Article III of the Constitution related to class-action suits against private defendants. In a 5–4 decision, the Court ruled that only those that can show concrete harm have standing to seek damages against private defendants.

References

  1. 1 2 3 "Haywood v. Drown - 07-10374 (2009)". Oyez: Chicago Kent College of Law. Retrieved 14 January 2014.
  2. "Haywood v. Drown - 07-10374 (2009)". JustiaL US Supreme Court Center. Retrieved 14 January 2014.