The US Supreme Court agreed recently that it would look into if a plaintiff has to exhaust all available state administrative remedies before taking up a federal civil rights claim before a court. The court will base its decision on the case, Williams v. Washington.
This case springs from a verdict in the Supreme Court of Alabama, which emphasized that individuals who filed unemployment compensation claims with the Alabama Department of Labor (ADOL) should have first used all legal remedies available through that state agency before filing a federal civil rights violation claim under 42 U.S.C. § 1983.
The plaintiffs, who contested the state court’s decision, stated that the Supreme Court of Alabama’s decision conflicts with the verdicts of various state supreme courts and contradicts this Court’s precedent. The precedent they were referring to is the 1982 decision from Patsy v. Board of Regents, in which the US Supreme Court stated that an individual does not have to first exhaust all state administrative remedies before bringing a federal civil rights violation claim under § 1983. The plaintiffs insist that the holding from Patsy extends to both state and federal courts.
The Alabama Supreme Court found in its June 2023 decision that it lacked jurisdiction over the § 1983 claim. The court cited that the Alabama legislature prohibited the courts from hearing cases from plaintiffs who had not first exhausted all administrative remedies before invoking § 1983. The court also rejected the plaintiff’s suggestion that Patsy‘s holding applied to state courts, considering that it was only intended to bind federal courts.
The over dozen Alabamians who filed this case claimed unemployment from ADOL. During their application process, they tested extreme delays and other irregularities. Some waited for several months for a response from ADOL, while others received no feedback about their claim.
Under normal circumstances, the plaintiffs would initially have to file a claim, which an ADOL examiner would then evaluate before making a determination. If the individual who filed the claim disagrees with that determination, they must request a hearing with the department’s “appeals tribunal”—an administrative adjudicative body—which reviews the dispute and any other due process complaints. The Supreme Court of Alabama’s findings state that the individual can seek another remedy, such as a § 1983 claim, only after the ADOL’s appeals tribunal issues a decision.
The US Supreme Court must now decide if the plaintiffs were right to bring their § 1983 claim before exhausting all state administrative remedies, or if the state court correctly interpreted Patsy.
Full details are available here.