Haywood v. Drown

556 U.S. 729 (2009)

Purchase the Printed Copy at bsmsphd.com

Nature of the Case

To access this section all you need to do is click here and register.

Facts

New York passed Correction Law §24. It required all prisoner’s §1983 claims to be brought in the court of claims as a claim against the state.' The Court of Claims is a court of limited jurisdiction. Plaintiffs in that court are not provided with the same relief, or the same procedural protections, made available in §1983 actions brought in state courts of general jurisdiction. Plaintiffs in the Court of Claims must comply with a 90-day notice requirement, are not entitled to a jury trial, have no right to attorney's fees, and may not seek punitive damages or injunctive relief. P is an inmate in New York's Attica Facility. P, in pro se, commenced two § 1983 actions against Ds alleging that they violated his civil rights in connection with three prisoner disciplinary proceedings and an altercation. P filed his claims in State Supreme Court and sought punitive damages and attorney's fees. The trial court dismissed the actions under N. Y. Correct. Law Ann. §24 for lack of jurisdiction. The intermediate appellate court summarily affirmed. The Court of Appeals also affirmed holding that the state law was valid as it treated state and federal law claims the same. It rejected P's argument that Correction Law § 24's jurisdictional limitation interfered with §1983 and therefore ran afoul of the Supremacy Clause of the United States Constitution. The Supreme Court granted certiorari.