[23-191] Williams v. Washington

Williams v. Washington

Wikipedia · Justia · Docket · oyez.org

Argued on Oct 7, 2024.

Petitioner: Nancy Williams, et al.
Respondent: Fitzgerald Washington, Alabama Secretary of Labor.

Advocates:

• Adam G. Unikowsky (for the Petitioners)
• Edmund G. LaCour, Jr. (for the Respondent)

Facts of the case (from oyez.org)

Dissatisfied with the Alabama Department of Labor’s handling of their unemployment benefits applications, 26 plaintiffs filed a complaint and motion for injunctive relief against Secretary Fitzgerald Washington and the Department. The plaintiffs, each having filed applications for benefits, alleged various grievances against the Department’s processing methods. Subsequently, Secretary Washington and the Department filed a motion to dismiss the complaint. In response, the plaintiffs amended their complaint, which resulted in the omission of several initial claims and the exclusion of the Department as a defendant.

The remaining allegations in the suit were federal claims under 42 U.S.C. § 1983, accusing Secretary Washington of implementing policies and procedures that violated both the Social Security Act of 1935, 42 U.S.C. § 503(a)(1), and the Due Process Clause of the Fourteenth Amendment. The plaintiffs sought various forms of relief, including multiple permanent and preliminary injunctions to expedite the handling of unemployment compensation applications and improve communication clarity, as well as attorney fees. Secretary Washington again moved to dismiss the case, citing reasons such as lack of subject-matter jurisdiction, absence of a private cause of action, and the substantive meritlessness of the claims. The court granted the dismissal without stating the basis for it. The plaintiffs moved to alter, amend, or vacate the judgment, but the court denied their motion. They then appealed to the Alabama Supreme Court, which affirmed the dismissal, concluding that the lower court lacked jurisdiction over the suit because the plaintiffs had not yet exhausted mandatory administrative remedies.

Question

Does a Section 1983 claim brought in state court require the plaintiffs to first exhaust state administrative remedies?