WASHINGTON (CN) — The Supreme Court ruled on Friday that a federal civil rights statute preempts Alabama’s requirement that an individual exhaust the state's administrative appeal process before suing in state court.
In a 5-4 opinion, Justice Brett Kavanaugh, wrote that Alabama’s exhaustion requirement created a catch-22 for residents, forcing them to complete an administrative process to claim unemployment benefits before they could challenge any delays in that process.
“Of course, that means you can never challenge delays in the administrative process,” the Donald Trump appointee said.
The high court's ruling turned on U.S. Code Section 1983 — which grants individuals the right to sue a state. The majority said that in the unusual circumstances when a court's application of an exhaustion requirement effectively immunizes officials from Section 1983 claims of deprivation of civil rights by people challenging administrative delays, state courts cannot then deny those claims on failure-to-exhaust grounds.
In a footnote, Kavanaugh said Friday’s ruling did not extend to premature procedural due process claims. He explained that the high court’s position remained that such claims are only ripe when a state ultimately fails to provide due process, not when a deprivation first occurs.
Kavanaugh was joined by Chief Justice John Roberts and justices Sonia Sotomayor, Elena Kagan and Ketanji Brown Jackson.
Justice Clarence Thomas, joined in part by justices Samuel Alito, Neil Gorsuch and Amy Coney Barrett, dissented.
Thomas, a George H. W. Bush appointee, wrote that the Alabama courts were right to dismiss the Section 1983 claims because the individuals had failed to complete the exhaustion process. States should have “unfettered discretion” over whether to hear such claims, Thomas said.
“Alabama’s exhaustion rule does not transgress the limitations that our precedents have recognized,” Thomas wrote. “The court concludes otherwise by endorsing an as-applied theory of futility that is both forfeited and meritless, moving our jurisprudence even further off course.”
Justices Alito, Gorsuch and Barrett joined Thomas in his contention that Alabama’s exhaustion requirements did not “run afoul” of precedent limiting a state’s authority to restrict federal claims proceeding in state courts.
The plaintiff coalition was made up of 21 residents who, at some point during the Covid-19 pandemic, were out of work and sought unemployment relief from the Alabama Department of Labor. In each case, the individuals faced lengthy wait times, received inconsistent benefits or received no benefits at all.
One of the plaintiffs in the case, Raymond Williams, contracted Covid in the summer of 2020 and was on a ventilator in intensive care for over a month. He requested a hearing but only received notice of the hearing while in the hospital. He could not file a timely appeal of his denial as he was on the ventilator when it occurred.
He tried submitting a new hearing request explaining his condition, but the request was denied, as his time in intensive care did not justify the late filing, according to the petitioners' brief.
Williams was joined in the suit by several residents who faced a myriad of hoops at the department in attempts to resolve different unemployment benefit issues.
Mark Johnson worked at a cemetery during the beginning of the pandemic and buried several people who died from Covid before contracting the illness himself. While he had to quarantine, his brother died. When he recovered, he asked about unpaid hazard pay and was fired.
Johnson applied for unemployment benefits, but the department told him he had been fired for insubordination and therefore was ineligible. Johnson tried to appeal but received no response until 2022, when he received an unfavorable decision.
The group filed suit in state court in Montgomery, Alabama, and requested injunctive relief directing the department to respond to their applications, schedule hearings within 90 days where appropriate and provide easily understandable information about the compensation program.
The department moved to dismiss the suit, arguing the group did not have standing as they had not exhausted the administrative remedies set by Alabama law. The state court agreed and dismissed the suit.
Soon after, the Supreme Court of Alabama affirmed the dismissal on the same grounds.
The majority reversed the Alabama Supreme Court’s ruling and remanded the case for further proceedings.
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