Haywood v. Drown
United States Supreme Court
556 U.S. 729 (2009)
Keith Haywood (plaintiff) was a prison inmate in a New York correctional facility, who brought two civil rights actions under 42 U.S.C. § 1983 against Curtis Drown (defendant) and other corrections officers, seeking punitive damages and attorney’s fees. Haywood acted pro se and filed the claims in the New York State Supreme Court, which dismissed the claims for lack of jurisdiction, pursuant to New York Correctional Law § 24, directing that claims against corrections officers must be brought against the state in the court of claims. Under state law, plaintiffs in the court of claims must follow strict requirements and are not entitled to a jury trial, attorney’s fees, punitive damages, or injunctive relief. The intermediate appellate court and New York Court of Appeals affirmed. The court of appeals upheld the law as valid, because it treated state and federal law claims the same. The United States Supreme Court granted certiorari on the issue of whether the state’s handling of § 1983 claims against corrections officers violated the Supremacy Clause of the United States Constitution.
Rule of Law
Holding and Reasoning (Stevens, J.)
Dissent (Thomas, J.)
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