In Williams v. Reed, published February 21, 2025, a divided U.S. Supreme Court reversed a state supreme court decision affirming dismissal of a lawsuit under 42 U.S.C. section 1983. A group of unemployed workers alleged that the state unlawfully delayed processing their state unemployment benefit claims. State law provided that state courts could not entertain appeals from decisions allowing or disallowing a claim for benefits unless the person filing the appeal had exhausted the administrative remedies under the suit. The claimants sought a court order requiring the state to speed up its administrative hearing process. The state courts dismissed the action on the ground that the plaintiffs had not exhausted the administrative hearing process.
The Supreme Court, 5-4, ruled that the exhaustion requirements as applied here had the effect of immunizing the state officials from suit under section 1983. Because the claimants cannot sue until they complete the administrative process, they can never sue under section 1983 to obtain an order expediting the administrative process. The majority emphasized that its ruling was narrow. Four dissenting justices opined that because states can choose whether to permit section 1983 suits in state court, the state court's decision was correct.
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