The question
Whether a state court may deny Section 1983 claims challenging delays in an administrative process on failure-to-exhaust grounds when the state exhaustion requirement effectively immunizes state officials from those claims.
Williams v. Reed
What the Court decided
The Court reversed the Alabama Supreme Court and remanded. Where a state court's application of a state exhaustion requirement in effect immunizes state officials from Section 1983 claims that challenge delays in the administrative process, state courts may not deny those claims on failure-to-exhaust grounds. A state law that immunizes conduct otherwise subject to suit under Section 1983 is preempted, even in state court, and Alabama's exhaustion requirement operated to immunize state officials from this narrow class of claims.
How the justices split
5-4The Court's opinion
Kavanaugh, joined by Roberts, Sotomayor, Kagan, Jackson
A state law that immunizes government conduct otherwise subject to suit under Section 1983 is preempted, even when the litigation takes place in state court. Alabama's exhaustion requirement barred state courts from reviewing delay claims under Section 1983 unless claimants first completed the administrative process, which operated to immunize state officials from a narrow class of Section 1983 claims. The jurisdictional label of the state rule is not dispositive, and requiring claimants to seek a writ of mandamus first is another form of the same barred exhaustion demand.
Dissenting in part
Thomas, joined by Alito, Gorsuch, Barrett
Thomas filed a dissenting opinion. Alito, Gorsuch, and Barrett joined as to Part II.
How we know · 5 sourced claims
The Court held that where a state exhaustion requirement in effect immunizes state officials from Section 1983 claims challenging administrative delays, state courts may not deny those claims on failure-to-exhaust grounds.
Source: syllabus, Held
A state law that immunizes government conduct otherwise subject to suit under Section 1983 is preempted, even where the federal civil rights litigation takes place in state court.
Source: syllabus, Held
The jurisdictional label of a state rule is not dispositive when the rule functionally immunizes defendants from a class of Section 1983 claims in state court.
Source: syllabus, Held
Kavanaugh delivered the opinion of the Court, joined by Roberts, Sotomayor, Kagan, and Jackson.
Source: syllabus, lineup
Thomas filed a dissenting opinion, which Alito, Gorsuch, and Barrett joined as to Part II.
Source: syllabus, lineup