Episode description

In this case, the court considered this issue: Does a Section 1983 claim brought in state court require the plaintiffs to first exhaust state administrative remedies?

The case was decided on February 21, 2025.

The Supreme Court held that where a state court’s application of a state exhaustion requirement in effect immunizes state officials from 42 U-S-C §1983 claims challenging delays in the administrative process, state courts may not deny those claims on failure-to-exhaust grounds. Justice Brett Kavanaugh authored the opinion of the Court on behalf of the 5-4 majority holding that Alabama may not enforce an administrative-exhaustion rule.

When a state law or rule functionally immunizes government officials from suits under § 1983, that law is preempted and unenforceable. Section 1983 ensures that individuals can seek a federal remedy for violations of their constitutional rights. Alabama’s exhaustion requirement, applied to delays in benefits processing, creates a procedural barrier that prevents claimants from ever challenging those delays under §1983. This precedent follows decisions in Haywood v Drown and Howlett v Rose, which held that states cannot erect procedural obstacles that effectively nullify federally guaranteed rights. The Alabama Supreme Court’s ruling in this case violated that principle by conditioning § 1983 suits on completing the very process claimants sought to challenge for unreasonable delay.

Characterizing Alabama’s rule as “jurisdictional” does not change this result. A state cannot use jurisdictional labels to avoid compliance with federal law, especially when the rule in question operates as an immunity provision. Nor does the potential availability of mandamus relief in Alabama courts justify the exhaustion rule, as requiring claimants to complete state-mandated processes before suing simply reinstates the same barrier. Because Alabama’s exhaustion rule functionally immunizes officials from § 1983 suits regarding administrative delays, it is preempted, and the judgment of the Alabama Supreme Court is reversed.

Justice Clarence Thomas authored a dissenting opinion, in which Justices Samuel Alito, Neil Gorsuch, and Amy Coney Barrett joined in part.

The opinion is presented here in its entirety, but with citations omitted. If you appreciate this episode, please subscribe. Thank you.