Haywood v. Drown

According to New York Corrections Law § 24 (“NYCL § 24”), New York state courts lack jurisdiction to hear private civil actions seeking monetary damages against a Department of Corrections (“DOCS”) employee, in his or her personal capacity, if the action is related to acts or omissions that fall within the scope of employment. Such claims can only be brought as claims directly against the State of New York in New York’s Court of Claims. NYCL § 24 has an exception for claims brought by the attorney general on behalf of the state. New York’s Court of Claims is a court of limited jurisdiction that only hears claims brought against New York State.

The practical effect of NYCL § 24 is to bar from New York state courts all 42 U.S.C. § 1983 claims against DOCS employees in their personal capacity unless the plaintiff is seeking declaratory or injunctive relief only or if the conduct at issue falls outside of the scope of employment. Title 42, § 1983 claims cannot be heard in New York’s Court of Claims because 42 U.S.C. § 1983 allows suits against individuals only.

This case involves the validity of NYCL § 24 under the Supremacy Clause of the U.S. Constitution. According to the Supremacy Clause, when state and federal law conflict, federal law preempts state law. According to Haywood, the New York statute is unconstitutional under the Supremacy Clause because it directly conflicts with 42 U.S.C. § 1983. In contrast, Drown argues that NYCL § 24 does not violate the Supremacy Clause because the New York statute regulates the jurisdiction of state courts, an area of state control with which Congress did not intend 42 U.S.C. § 1983 to interfere.

Neutral Jurisdictional Rules and the Supremacy Clause

States can limit enforcement of a federal right without violating the Supremacy Clause if they have a “valid excuse” for doing so. ( One such excuse is when a state removes jurisdiction over federal claims by way of a “neutral state rule regarding the administration of the courts.” The New York Court of Appeals considered NYCL § 24 to be such a neutral jurisdictional rule and as a result, found no Supremacy Clause violation. to Drown, this determination by the highest court in New York is entitled to great deference. Furthermore, Drown argues that NYCL § 24 is jurisdictional in nature because it addresses state courts’ competence over subject matter, specifically the liability of certain state employees for conduct committed within the scope of their employment. According to Drown, decisions over what subject matter can be heard in what courts are the specific issues that “jurisdictional rules are designed to protect.” In addition, Drown argues that NYCL § 24 is clearly jurisdictional in nature because it assigns a particular subset of claims to a particular court, namely the New York Court of Claims.

However, Haywood argues that NYCL § 24 is a substantive rule, and not primarily jurisdictional in nature, and therefore is not immune from Supremacy Clause concerns. According to Haywood, to be considered a neutral jurisdictional rule, a statute must address the court’s “power over the person and competence over the subject matter.” Haywood argues that the New York statute is not related to the court’s competence over subject matter because NYCL § 24 removes only a small subset of claims from state court jurisdiction, leaving state courts with the authority to hear many claims of a similar nature. Furthermore, Haywood suggests the statute does not address the court’s power over the person because it leaves state courts responsible for claims almost identical to the ones barred by NYCL § 24, such as 42 U.S.C. § 1983 claims against non-DOCS state employees and all 42 U.S.C. § 1983 claims against state employees, including DOCS employees, that seek injunctive relief only or that involve conduct falling outside of the scope of their employment. According to Haywood, states cannot escape supremacy clause constitutional obligations “by the simple device of removing jurisdiction from courts otherwise competent.” For these reasons, Haywood argues that NYCL § 24 is not jurisdictional in nature but is rather an immunity statute for prison employees.

Drown also argues that the New York statute is a valid and neutral rule because it treats federal and state law claims the same. According to Drown, a state can limit the jurisdiction of its courts over federal claims without violating the Supremacy Clause as long as the state limits jurisdiction over analogous state law claims. The Court of Appeals of New York endorsed this “nondiscrimination principle” and held NYCL § 24 to be valid under the Supremacy Clause because it bars from state court both federal and state claims against DOCS employees in their personal capacity for conduct falling within the scope of employment.

According to Haywood, the Court of Appeals of New York erred in determining that the Supremacy Clause requires nothing more than treating state and federal claims alike. Such a test, Haywood argues, “turns the supreme law of the land into a menu from which states may freely pick and choose, depending on their own priority and views.” According to Haywood, the Supremacy Clause prevents a state from overriding federal law based on its “substantive disagreement” over federal priorities, even if it is done in such a way as to treat state and federal claims alike. In support of this argument, Haywood points to prior United States Supreme Court cases that struck down state laws that conflicted with federal priorities, even when the laws applied equally to state and federal claims.

State Policy Interests and Congressional Intent

Drown’s argument in support of NYCL § 24 emphasizes New York’s important policy interests behind the statute, including the “sound judicial and prison administration” of the state courts.According to Drown, courts have recognized that there are few issues more important to the state than administration of its prisons.

However, Haywood argues that state laws are invalid under the Supremacy Clause if they upset the purpose of the federal laws, regardless of the state interest served. According to Haywood, NYCL § 24 frustrates Congress’ purpose behind 42 U.S.C. § 1983, which was specifically to safeguard civil rights by allowing private parties to directly sue individuals who violated those rights. Furthermore, Haywood argues that NYCL § 24 further contravenes Congressional intent by limiting the remedies available to individuals who sue DOCS employees for conduct that falls within the scope of their employment. Cases in the New York Court of Claims are not heard before a jury trial and punitive damages, attorney’s fees, and other remedies that are otherwise available under 42 U.S.C. § 1983 are limited. As a result, Haywood argues, Congress’ efforts to provide for certain remedies through 42 U.S.C. § 1983 are less likely to be realized.

In contrast, Drown argues that NYCL § 24 does not contravene Congress’ intent because Congress did not intend 42 U.S.C. § 1983 to limit a state’s ability to control the jurisdiction of its courts. If 42 U.S.C. § 1983 was designed to have such an impact on state sovereignty, Drown argues, Congress would have had to make this intention clear in the language of the statute. , Since there is no such statement in 42 U.S.C. § 1983, according to Drown, the state maintains all rights to control the subject matter jurisdiction of its courts. Furthermore, Drown argues that NYCL § 24 does not run counter to Congress’ purpose behind 42 U.S.C. § 1983 because Congress intended federal courts to have a “paramount role” in the enforcement of those rights protected by the civil rights statute. Since NYCL § 24 does not limit the rights of individuals to bring suits against DOCS employees in federal court, where all the rights and remedies under 42 U.S.C. § 1983 are available, Drown argues that New York’s statute does not contravene Congressional intent.