556 U.S. 729 (2009)
New York enacted Correction Law §24 motivated by the belief that damages suits filed by prisoners against state correction officers were largely frivolous and vexatious.1 The statute divests state courts of jurisdiction over damages actions against correction officers for acts within the scope of employment and requires such claims to be brought instead in the Court of Claims against the state.2
Petitioner, an inmate in New York’s Attica Correctional Facility, commenced two §1983 actions against several correction employees.3 He alleged that they violated his civil rights in connection with three prisoner disciplinary proceedings and an altercation.4 Proceeding pro se, petitioner filed his claims in State Supreme Court and sought punitive damages and attorney’s fees.5
The trial court dismissed the actions for lack of jurisdiction under Correction Law §24.6 The intermediate appellate court summarily affirmed.7 The New York Court of Appeals affirmed by a 4-to-3 vote, reasoning that the statute was a neutral rule because it treated state and federal claims equally.8 Judge Jones dissented on the ground that the state could not selectively exclude §1983 actions by labeling policies as jurisdictional.9
Recognizing the importance of the question, the Supreme Court granted certiorari.1011
Whether New York Correction Law §24, as applied to §1983 claims, violates the Supremacy Clause?12
A State cannot employ a jurisdictional rule to dissociate itself from federal law because of disagreement with its content or a refusal to recognize the superior authority of its source.13 Equality of treatment is necessary but not sufficient when the state maintains courts competent to hear similar federal actions.14
Yes. New York enacted Correction Law §24. It was motivated by the belief that damages suits filed by prisoners against state correction officers were largely frivolous and vexatious. The statute provides that no civil action shall be brought in any court of the state against any officer or employee of the department for damages arising out of acts within the scope of employment.15 Such claims shall instead be brought in the Court of Claims against the state.16 Petitioner, an inmate at Attica Correctional Facility, commenced two §1983 actions against correction employees alleging violations of his civil rights in connection with disciplinary proceedings and an altercation.17
Proceeding pro se, he filed in State Supreme Court seeking punitive damages and attorney's fees.18 The trial court dismissed the actions for lack of jurisdiction under Correction Law §24. The intermediate appellate court summarily affirmed the trial court.19 The New York Court of Appeals affirmed by a 4-to-3 vote, holding that the statute was a neutral rule of judicial administration because it treated state and federal claims equally.20
Judge Jones dissented, arguing that once a state opens its courts to hear section 1983 actions it may not selectively exclude them by denominating state policies as jurisdictional.21 The Supreme Court granted certiorari. The Supremacy Clause, as interpreted in precedents such as Howlett v. Rose, prohibits states from nullifying federal causes of action based on local policy disagreements.22 New York Correction Law §24 was enacted to shield correction officers from damages suits that the state viewed as frivolous.23
This policy directly conflicts with Congress's judgment in §1983 that all persons acting under color of state law who violate federal rights shall be liable for damages.24 Although the statute applies equally to state and federal claims, equality of treatment is not sufficient when the state has created courts of general jurisdiction that routinely hear analogous §1983 actions against other officials.25 By divesting those courts of jurisdiction over this category of claims, New York has effectively used a jurisdictional rule to evade its obligation to enforce federal law.26
Correction Law §24 violates the Supremacy Clause as applied to §1983 claims.27
Related opinions on this issue
Joined by Roberts, C. J., And Scalia And Alito, Jj.
Justice Thomas dissented on the ground that neither Article III nor the Supremacy Clause imposes any duty on state courts to entertain federal causes of action.28 He explained that the Madisonian Compromise left states with plenary authority to define the subject-matter jurisdiction of their own courts, and that the Supremacy Clause supplies only a rule of decision when jurisdiction exists under state law.29 Thomas argued that New York Correction Law §24 is a true jurisdictional bar that treats federal and state claims identically and therefore does not offend the Supremacy Clause.30
He criticized the majority for extending the antidiscrimination principle beyond the holdings of Claflin, Second Employers' Liability Cases, and Douglas, and for effectively requiring states to maintain jurisdiction over any federal claim once they have created courts of general jurisdiction.31