Constitutional Law: Off the Clock, On the Docket: A Legal Analysis of Supreme Court Labor Decision - Williams v. Reed

Written by Cole Frey, Dashaun Brown, Rowen Hamilton, Munpreet Kaur, Yaquelin Hinojosa-Fuentes

Edited by Rowen Hamilton and Anna Ramesh

Background and Overview

Nancy Williams—along with 26 other unemployed residents of Alabama—filed a class action lawsuit against Alabama's Secretary of Labor. The plaintiffs claimed that Secretary Fitzgerald Washington unlawfully delayed the processing of the group's state unemployment claims under 42 U. S. C. §1983. They claimed this violated the Due Process Clause of the Fourteenth Amendment and the Social Security Act of 1935. Secretary Washington filed a motion to dismiss the complaint on the grounds that the state lacked jurisdiction and substantive claims. The Alabama Court of Civil Appeals denied the appeal. The Alabama Supreme Court granted dismissal of the suit on the grounds that the lower court lacked jurisdiction over the case because the plaintiffs had not yet exhausted mandatory administrative remedies.

Upon reviewing a writ of certiorari from the plaintiffs, the SCOTUS addressed the question of whether Section 1983 claims brought in state court would first require the plaintiffs to exhaust state administrative remedies. Under Alabama Code §25–4–95 of Alabama law, the claimant may challenge the denial of benefits in state court only when all other administrative remedies have been exhausted. The statute prohibits Alabama circuit courts from "[permitting] an appeal…unless the person filling such appeal has exhausted his administrative remedies..." (2006 Alabama Code). The state's requirement prevents claimants from suing in state courts until a decision from an appeals tribunal has been issued. In this case, Williams v. Reed first went to the Circuit Court of Montgomery County, Alabama, the trial court for their county. Then, they appealed to the Alabama Supreme Court as an intermediate appellate court. Lastly, the case made its way to the United States Supreme Court—the final appellate court.

In a 5-4 Decision, The Supreme Court of the United States ruled in favor of the plaintiff. The Court argued that in circumstances where a state court's application of the state's aforementioned exhaustion requirement in §25–4–95 that immunizes state officials from §1983, state courts may not deny those claims on failure-to-exhaust grounds. The Court declared that Section 1983 allows individuals to seek federal remedy for violations of their constitutional rights and that Alabama's exhaustion requirement creates a procedural barrier preventing claimants from challenging administrative delays. The court agreed with the plaintiff that his rule creates a complicated situation in which the claimants are unable to sue to obtain an order to expedite the administrative process because they had not yet completed the process allegedly being delayed. Finally, the Court cited multiple cases in which the prevailing precedent has been that §1983 preempted a series of state statues, arguing that States "lack authority to nullify a federal right or cause of action they believe is inconsistent with their local policies" and that States have "No authority to override" Congress's ability to subject officials to "liability for violations of federal rights" (Williams v. Reed).

Precedent

Felder v. Casey (1988)

Robert Felder—the petitioner—believed that Wisconsin police—the defendant—violated his 4th and 14th Amendment rights during a physical encounter that occurred nine months prior. As a Black man, Felder claimed that the police acted with excessive force, and Duane Casey—the City Attorney of Milwaukee, Wisconsin—represented the city and its police force. However, Wisconsin argued that the defendant had waited too long to bring the suit under a preexisting notice-to-claim rule—a state requirement that outlines when certain parts of lawsuits have to be submitted to the state—and concluded that the lawsuit should not be heard. The Milwaukee County Circuit Court dismissed the case, and the appellate ruling in the Wisconsin supreme Court upheld this dismissal. The case was ultimately appealed to the Supreme Court.

The SCOTUS ruled against Wisconsin in a 7-2 decision authored by Justice Brennan. They held that the Wisconsin law—the notice-of-claim rule—made federal law inconsistent between states. The SCOTUS ruled that states cannot create unreasonable extra barriers that make it harder to uphold constitutional rights because this practice would undermine federal protections. The majority ruled that state courts cannot refuse to hear §1983 cases by appealing to a federalist principle of state judicial authority.

Howlett v. Rose (1990)

James Rose—a public school official—received a tip that a student—Kevin Howlett—had fireworks in his car and searched it without a warrant. Howlett alleged that the school board violated his 4th and 14th Amendment rights when they conducted a search of his vehicle. However, the school—vested with Florida state authority—claimed itself to have sovereign immunity and that the state court did not have jurisdiction to bring a §1983 case. The SCOTUS ruled that the Supremacy Clause of the Constitution determines that states cannot pick and choose when to follow federal laws. It ruled that if Florida hears lawsuits against private parties, it must also hear cases against state agencies under federal law. Deferring this responsibility would otherwise weaken civil rights protections.

The majority in Williams v. Reed agrees with the logic in Howlett v. Rose. The federal government has the authority to rule that states cannot grant themselves sovereign immunity from §1983 lawsuits even if states have broad authority over their own courts.

Haywood v. Drown (2009)

Randy Haywood—an inmate in New York State Prison—was charged with assault on a corrections officer (Steven Drown), failure to pass a urinalysis test, and the improper solicitation of mail. As a response, Haywood alleged conspiracy and that his corrections officers were violating his civil rights under §1983. However, New York's Correction Law § 24 granted corrections officers—when acting in their official capacities—immunity from §1983 claims in state court. New York's and dismissed the case to a claims court where only monetary damages could be sought. However, the SCOTUS ruled that it was unconstitutional to rule out a specific type of case outright (ie. all §1983 claims against state corrections officers). They found that state courts can't discriminate against federal claims and treat them differently from similar state-law claims because this weakened their ability to seek justice.

The majority in Williams v. Reed drew upon this case to suggest that states do not have the authority to wholly exclude §1983 federal lawsuits that prosecute state agents and agencies.

Effects of Williams v. Reed

Citizens cannot be deprived of due process for a state to decide a complaint for remedy, as in Williams v. Reed. A remedy is not guaranteed, but the process that decides if one is entitled or not to a remedy is a right. In Williams v. Reed, the plaintiffs' delayed benefits were considered withheld property. The verdict is that a state cannot sidestep a person's right to due process and cannot enforce statutes, policies, or court decisions with impossible requirements. This standard would deprive due process even if a state has certain rights to administration and jurisdiction within its courts.

Williams v. Reed (2025) grows from the framework of the SCOTUS decisions based on the Fourteenth Amendment's Due Process Clause and the Supremacy Clause. As Judge Kavanaugh writes in the majority opinion, states cannot simply dismiss a federal case due to local laws. By barring states from invoking their exhaustion requirements as a defense to §1983, the SCOTUS decision weakens state power while maintaining their agency and official responsibility for handling claims, particularly claims for unemployment benefits or other entitlements.

Terms and Definitions

42 U.S. Code § 1983 (Title 42, Section 1983). The statute that enforces the following principle: if an entity has purportedly had their rights or entitlements withheld, then the withholding party can be held civilly accountable for damages.

14th Amendment Due Process Clause. "…nor shall any State deprive any person of life, liberty, or property, without due process of law…" (Library of Congress) The Fourteenth Amendment's Due Process Clause provides that no state may deprive any person of life, liberty, or property, without due process of law. Although the language is similar to the Fifth Amendment, the Fourteenth Amendment applies to state government actions. The Fourteenth Amendment's Due Process Clause guarantees procedural due process, meaning that government actors must follow certain procedures before they may deprive a person of a protected life, liberty, or property interest.

Alabama Code §25–4–95. Statute about the process for seeking review of unemployment benefits from an appeals tribunal. If a party has not received entitled benefits, they are required to file an appeal for a state tribunal to review before suing the government.

Appellate. A court or decision that appeals or reviews a decision made in a previous case or decision.

Plaintiff. In a civil matter, the party who initiates a lawsuit against the defendant.

Sovereign Immunity. a common law doctrine under which a sovereign entity like a government cannot be sued without its consent.

Supremacy Clause. The clause in Article VI of the Constitution that explains how when federal and state law conflict with each other, the federal law should prevail.

The Social Security Act (1935). The law enacted during the great depression that provided welfare benefits based on age, disability, health, dependency status, and employment status.

Writ of Certiorari. A review of a case decided and delivered by a lower court.