Nahmod Law

The Supreme Court’s 2009 decision in Haywood v. Drown was a surprisingly close decision that pitted the Supremacy Clause against federalism, with the former barely winning.

The Decision

Haywood v. Drown, 129 S. Ct. 2108 (2009), dealt with a New York statute that provided that New York courts did not have jurisdiction to hear any claims for damages against correctional officials sued in their personal capacities for acts committed within the scope of their employment, while allowing the State to be sued under state law in its Court of Claims for such claims. The Court of Appeals of New York had ruled that New York courts lacked jurisdiction to hear the plaintiff inmate’s two § 1983 complaints seeking damages against correctional officers. This did not violate the Supremacy Clause because the relevant New York statute did not discriminate against federal causes of action but covered all such claims, whether based on state or federal law. This provision was “neutral” for Supremacy Clause purposes, according to the Court of Appeals: “New York courts necessarily adjudicate only state claims brought against the state and federal courts adjudicate only federal causes of action brought against individuals.” Read the rest of this entry »