The US Supreme Court agreed Friday to determine whether a plaintiff must first exhaust all state administrative remedies before bringing a federal civil rights claim before a court. The case, Williams v. Washington, stems from a decision in the Supreme Court of Alabama which held that individuals who filed unemployment compensation claims with the Alabama Department of Labor (ADOL) should have first exhausted all legal remedies available through that state agency before filing a federal civil rights violation claim under 42 U.S.C. § 1983.
The Alabama plaintiffs who challenged the state court’s decision argue, “[T]he Supreme Court of Alabama’s decision conflicts with the decisions of several state supreme courts and defies this Court’s precedent.” The precedent being referred to is the 1982 decision from Patsy v. Board of Regents, in which the US Supreme Court held 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 in Williams assert that the holding from Patsy extends to both state and federal courts.
In its June 2023 decision, the Alabama Supreme Court found that it lacked jurisdiction over the § 1983 claim. The court reasoned 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 balked at the plaintiff’s suggestion that Patsy‘s holding applied to state courts, finding instead that it was only meant to bind federal courts.
The Supreme Court of Alabama’s decision upheld the findings of both the trial court and the appellate court, meaning the plaintiffs’ last potential avenue of legal review was the US Supreme Court.
The plaintiffs in this case are over a dozen Alabamians who filed unemployment claims with the ADOL. During their application process, the petitioners “experienced extreme delays and other irregularities.” Some petitioners waited for months for a response from the ADOL, while others simply never heard back about their claim.
Under normal processes, the plaintiffs would first be required to file a claim, which would then be evaluated by an ADOL examiner before a determination is made. If the individual who filed the claim objects to that determination, they are required to seek a hearing with the department’s “appeals tribunal”—an administrative adjudicative body—which reviews the dispute and any other due process complaints. It is only after the ADOL’s appeals tribunal issues a decision that the individual can seek another remedy, such as a § 1983 claim, according to the Supreme Court of Alabama’s findings.
It is now up to the US Supreme Court to determine whether the plaintiffs were correct in bringing their § 1983 claim before exhausting all state administrative remedies, or if the state court is correct in their reading of Patsy.
