Williams v. Washington

Williams v. Washington
Supreme Court of the United States
Full case name	Nancy Williams, et al. v. Fitzgerald Washington, Alabama Secretary of Labor
Docket no.	23-191
Case history
Prior	Johnson v. Alabama Secretary of Labor, Fitzgerald Washington, (Ala. 2023)
Questions presented
Whether exhaustion of state administrative remedies is required to bring claims under 42 U.S.C. § 1983 in state court.

Williams v. Washington (Docket No. 23-191) is a pending United States Supreme Court case related to 42 U.S.C. § 1983.

Background

The Enforcement Act of 1871, also known as the Ku Klux Klan Act, is a federal law aimed at combating the violence and intimidation tactics used by the Ku Klux Klan to interfere with the civil rights of African Americans during the Reconstruction era, empowering the federal government to intervene and protect those rights. Section 1 of the Act, amended and codified at 42 U.S.C. § 1983 and commonly known as "Section 1983", allows individuals to sue state or local government officials, including law enforcement officers, for violations of their constitutional rights. It provides a legal remedy for individuals who believe their rights, as protected by the U.S. Constitution, have been violated by persons acting under the color of state law. In the time since its passing, Section 1983 has become the most widely used civil rights enforcement statute. In Haywood v. Drown, the Supreme Court held that Section 1983 suits may be heard in either state or federal courts.

The laws of Alabama provide for an unemployment compensation benefits scheme. Any Alabama resident seeking such benefits must file an application with the Alabama Department of Labor. A department examiner will make a determination with respect to each applicant's claim, either specifying how much the claimant is entitled to receive, or explaining why the claimant's application was denied. The claimant may appeal their determination to an appeals tribunal, which is composed of employees of the Department of Labor who are charged with adjudicating disputed claims. In addition to the appeals tribunals, the department has created a board of appeals which may delegate—either to itself or to another appeals tribunal—any claim that is pending before an appeals tribunal. In either case, the appellate body must notify the parties in writing of its findings of fact, its decision, and the reasons for its decision. This statutory scheme includes the requirement that, prior to having their claims heard in a court of law, applicants must exhaust all administrative remedies provided by law.

Lower court history

Petitioners, including Nancy Williams, are Alabama unemployment compensation benefits claimants. Despite the statutory requirements that parties be notified promptly regarding the dispositions of their claims, the Department of Labor often took months in making its initial determinations regarding benefits eligibility, with some petitioners never receiving any determination regarding their claims. Some petitioners' benefits were stopped with little or no prior notice. Some petitioners failed to have hearings scheduled where they could dispute the Department's determinations.

Petitioners filed suit under Section 1983 in Montgomery County, Alabama, claiming that the Department of Labor violated both their constitutional right to due process, and their federal rights under the Social Security Act of 1935. Petitioners sought injunctive relief, including an injunction directing the Alabama Secretary of Labor, Fitzgerald Washington, to issue prompt decisions on applicants' claims. Washington moved to dismiss the suit on the grounds that petitioners had not exhausted their administrative remedies before bringing suit in Circuit Court—the Court granted the motion to dismiss, and denied petitioners' motion to reconsider. The Alabama Supreme Court affirmed the dismissal on the grounds that petitioners failed to exhaust their state administrative remedies before bringing suit.

Supreme Court

On August 28, 2023, Williams petitioned the Supreme Court to hear her case. On January 12, 2024, the court granted certiorari.