Felder v. Casey case brief

Felder v. Casey case brief summary
487 U.S. 131 (1988)

CASE SYNOPSIS

Certiorari was issued to the Supreme Court of Wisconsin to determine whether the court properly held that Wisconsin's notice-of-claim statute applied to federal civil rights actions brought in state court under 42 U.S.C.S. §1983.

DISCUSSION

• The court reversed a judgment granting respondent officers' motion to dismiss a suit pursuant to 42U.S.C.S. §1983 based on petitioner's failure to comply with the state's notice-of-claim statute. 
• The notice-of-claim statute provided that no action could be brought against the state government unless the claimant either provided written notice of the claim within 120 days of the alleged injury, or demonstrated that the government had actual notice of the claim. 
• The court found that the statute conflicted with the remedial objectives of §1983, and that its enforcement in such actions would produce different outcomes in §1983 litigation based solely on whether the claim was asserted in state or federal court. 
• The court stated that the application of the notice requirement burdened the exercise of the federal right by forcing civil rights victims who sought redress in state courts to comply with a requirement that was entirely absent from civil rights litigation in federal courts. 
• The court found that the notice provision impermissibly operated as an exhaustion requirement, in that it forced claimants to seek satisfaction in the first instance from the governmental defendant.

CONCLUSION
The court reversed and remanded the judgment granting respondents' motion to dismiss the action because the state's notice-of-claim statute conflicted in both its purpose and effects with the remedial objectives of federal civil rights laws, and was thereby pre-empted when the action was brought in a state court.


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