WILLIAMS ET AL. v. REED, ALABAMA SECRETARY OF WORKFORCE
No. 23-191
Supreme Court of the United States
February 21, 2025
604 U. S. ____ (2025)
CERTIORARI TO THE SUPREME COURT OF ALABAMA
Syllabus
NOTE: Where it is feasible, a syllabus (headnote) will be released, as is being done in connection with this case, at the time the opinion is issued. The syllabus constitutes no part of the opinion of the Court but has been prepared by the Reporter of Decisions for the convenience of the reader. See United States v. Detroit Timber & Lumber Co., 200 U. S. 321, 337.
SUPREME COURT OF THE UNITED STATES
Syllabus
WILLIAMS ET AL. v. REED, ALABAMA SECRETARY OF WORKFORCE
CERTIORARI TO THE SUPREME COURT OF ALABAMA
No. 23-191. Argued October 7, 2024—Decided February 21, 2025
Petitioners are unemployed workers who contend that the Alabama Department of Labor unlawfully delayed processing their state unemployment benefits claims. They sued the Alabama Secretary of Labor in state court under
Held: Where a state court‘s application of a state exhaustion requirement in effect immunizes state officials from
(a) “[A] state law that immunizes government conduct otherwise subject to suit under
(b) Under Alabama‘s exhaustion requirement, state courts cannot review claims of unlawful delays under
(c) According to the Secretary, the jurisdictional nature of Alabama‘s exhaustion provision distinguishes it from the state rules at issue in Haywood and Howlett. But this Court‘s precedents have not treated the jurisdictional label of state rules as dispositive when state rules functionally immunize defendants from a class of
Next, the Secretary suggests that any delays in the state administrative process can be cured by claimants’ seeking a writ of mandamus from the state courts to compel the Department to act more quickly. It is not evident, however, that mandamus is available to the claimants here. In any event, the Secretary‘s argument is simply another way of saying that the claimant must go through the state process before suing under
387 So. 3d 138, reversed and remanded.
KAVANAUGH, J., delivered the opinion of the Court, in which ROBERTS, C. J., and SOTOMAYOR, KAGAN, and JACKSON, JJ., joined. THOMAS, J., filed a dissenting opinion, in which ALITO, GORSUCH, and BARRETT, JJ., joined as to Part II.
Opinion of the Court
NOTICE: This opinion is subject to formal revision before publication in the United States Reports. Readers are requested to notify the Reporter of Decisions, Supreme Court of the United States, Washington, D. C. 20543, pio@supremecourt.gov, of any typographical or other formal errors.
SUPREME COURT OF THE UNITED STATES
No. 23-191
NANCY WILLIAMS, ET AL., PETITIONERS v. GREG REED, SECRETARY, ALABAMA DEPARTMENT OF WORKFORCE
[February 21, 2025]
JUSTICE KAVANAUGH delivered the opinion of the Court.
Several unemployed workers in Alabama applied for unemployment benefits from the State. In their view, the Alabama Department
I
A
The State of Alabama grants monetary benefits to unemployed claimants who meet certain eligibility criteria. See
A claimant who wants to appeal an adverse determination must, within 7 days of the delivery of the notice or 15 days of the mailing of the notice, seek review by an appeals tribunal.
A claimant who loses before the appeals tribunal may seek discretionary review before the Department‘s Board of Appeals, which is composed of three members appointed by the Governor.
review within 15 days from the date when the appeals tribunal‘s decision was mailed to the claimant.
After the Board of Appeals denies review, fails to grant review within the 10-day period, or grants review and issues an adverse decision, the claimant may then challenge the denial of benefits in Alabama state court.
“No circuit court shall permit an appeal from a decision allowing or disallowing a claim for benefits unless the decision sought to be reviewed is that of an appeals tribunal or of the board of appeals and unless the person filing such appeal has exhausted his administrative remedies as provided by this chapter.” Ibid.
That statutory procedure “shall be exclusive.”
B
In this case, 21 Alabama claimants applied for unemployment benefits. They contend that the Department, in various ways, has unlawfully delayed the processing of their benefits claims. For example, plaintiff Derek Bateman alleges that he attempted to appeal his claim to an appeals tribunal. But according to Bateman, the Department never scheduled a hearing or otherwise acted on his appeal, even after he attempted to follow up by email and phone calls numerous times.
The 21 claimants sued the Secretary of Labor in his official capacity in the Circuit Court of Montgomery County, Alabama. Invoking
The claimants did not ask the court to rule that they were entitled to unemployment benefits. Rather, they simply asked the court to order the Department to promptly address their benefits claims. As relevant here, the claimants sought a court order requiring the Department to: (1) “issue an initial nonmonetary decision within the next ten days to every plaintiff who has not yet received a decision“; (2) “provide within ten days a hearing date for each of the plaintiffs who [has] requested a hearing“; (3) schedule such hearings for a date not later than 90 days after the request for the hearing; and (4) pay every approved claim within two days of the date of approval. App. 42-43.
The Secretary moved to dismiss the complaint on several grounds. The Secretary argued, among other things, that the state trial court lacked jurisdiction because the claimants had not satisfied the administrative-exhaustion requirement in
The claimants appealed to the Alabama Supreme Court. That court affirmed on failure-to-exhaust grounds. Johnson v. Washington, 387 So. 3d 138, 144 (Ala. 2023). The court concluded that under this Court‘s precedents,
Justice Cook dissented. He reasoned that under this Court‘s
This Court granted certiorari. 601 U. S. ____ (2024).
II
The Secretary argues that Alabama‘s exhaustion requirement constitutes a “neutral rule of judicial administration” and that the Alabama Supreme Court permissibly applied that statutory rule to bar the claimants’
In light of this Court‘s precedents, we agree with the claimants. In the unusual circumstances presented here—where a state court‘s application of a state exhaustion requirement in effect immunizes state officials from
A
This Court has long held that “a state law that immunizes government conduct otherwise subject to suit under
487 U. S. 131, 139 (1988). As the Court has explained, States possess “no authority to override” Congress‘s “decision to subject state” officials “to liability for violations of federal rights.” Id., at 143. That principle bars any state rule immunizing state officials from a “particular species” of federal claims, even if the immunity rule is “cloaked in jurisdictional garb.” Haywood, 556 U. S., at 739, 742.
In Howlett v. Rose, for example, the Court analyzed a Florida rule extending the State‘s sovereign immunity from
And in Haywood v. Drown, the Court addressed a New York statute depriving state courts of jurisdiction over claims by prisoners seeking damages against state correctional officers. See 556 U. S., at 733-734. The Court reiterated that States “lack authority to nullify a federal right or cause of action they believe is inconsistent with their local policies.” Id., at 736. In violation of that principle, New York in essence had created “an immunity defense” for correctional officers when those officers were sued under
Here, the Alabama Supreme Court ruled that the State‘s exhaustion requirement applies to “procedural challenges related to the administration of unemployment-compensation benefits in addition to substantive challenges regarding the decision to award (or not award) those benefits.” Johnson v. Washington, 387 So. 3d 138, 143 (2023). And it concluded that the universe of “procedural challenges” requiring exhaustion includes
Alabama‘s exhaustion requirement operates to immunize state officials from a narrow class of claims brought under
Under this Court‘s precedents, however, Alabama cannot maintain such an immunity rule. As this Court‘s cases have repeatedly held, “a state law that immunizes government conduct otherwise subject to suit under
general jurisdiction that routinely sit to hear analogous
also Howlett, 496 U. S., at 375-378.4
C
In response, the Secretary advances two primary points.
First, the Secretary argues that the “jurisdictional nature of Alabama‘s exhaustion provision sets it apart from procedural rules that may be more readily preempted by
States “retain substantial leeway to establish the contours of their judicial systems” and are free to enforce “neutral” jurisdictional rules. Haywood, 556 U. S., at 735-736. The Secretary‘s argument fails, however, because this
explained, New York‘s law operated as “an immunity statute cloaked in jurisdictional garb.” Id., at 742. To treat the jurisdictional label as dispositive would allow the Supremacy Clause to be “evaded.” Ibid.; see also Howlett, 496 U. S., at 383.
Second, the Secretary suggests that the claimants could seek a writ of mandamus from the state courts to compel the Department to act more quickly. For that reason, the Secretary says that any delays in the state administrative process can be cured within the state judicial system.
To begin with, it is not evident that mandamus is available to the claimants here. The Secretary cites a lone decades-old case from an Alabama intermediate appellate court suggesting in dicta that mandamus would be “appropriate” in a case where a state agency intentionally delayed its decision on a couple‘s application to become adoptive parents. Vance v. Montgomery Cty. Dept. of Human Resources, 693 So. 2d 493, 495 (Ala. Civ. App. 1997). If mandamus relief were available in these unemployment benefits cases, one would have expected the Alabama Supreme Court to say so in its opinion here. Yet the court did not say or suggest that mandamus relief would be available.
In any event, the Secretary‘s argument based on the supposed availability of mandamus is simply another way of saying that the claimant must go through the process provided by the State before suing under
sue for injunctive relief under
For its part, the dissent largely discusses issues that we do not address in this opinion. In Part II-C-2, when the dissent eventually turns to the merits of our legal analysis, the dissent argues that Haywood‘s reasoning about immunity rules applies only where a “focus on statutory purpose” reveals that a state rule reflects “policy disagreement” with federal law. Post, at 11 (opinion of THOMAS, J.) (quoting Haywood, 556 U. S., at 737-738). We respectfully disagree with the dissent‘s reading of Haywood. That decision did not endorse a freewheeling inquiry into whether a state rule‘s “purpose” or “policy” (however assessed) is at odds with federal law. Rather, a state rule runs afoul of Haywood if it operates as an “immunity statute cloaked in jurisdictional garb” by wholly barring a “particular species” of
The dissent also suggests that the claimants forfeited their argument based on Haywood and Howlett in the Alabama Supreme Court. In that court, however, the claimants clearly raised the argument that under
The dissent further says that our opinion may have “ripple effects.” Post, at 12. But as we have emphasized, our opinion today is narrow; it resolves this dispute but is careful not to go beyond this Court‘s existing precedents. See n. 2, supra.
*
*
*
The Alabama Supreme Court interpreted the State‘s administrative-exhaustion requirement for unemployment
benefits claims to in effect immunize the Alabama Secretary of Labor from
It is so ordered.
THOMAS, J., dissenting
SUPREME COURT OF THE UNITED STATES
No. 23-191
NANCY WILLIAMS, ET AL., PETITIONERS v. GREG REED, SECRETARY, ALABAMA DEPARTMENT OF WORKFORCE
ON WRIT OF CERTIORARI TO THE SUPREME COURT OF ALABAMA
[February 21, 2025]
JUSTICE THOMAS, with whom JUSTICE ALITO, JUSTICE GORSUCH, and JUSTICE BARRETT join as to Part II, dissenting.
Alabama law requires claimants seeking unemployment benefits to exhaust their administrative remedies before suing over those benefits in state court. Petitioners, the claimants here, failed to complete that process before they sued under
I
This case is straightforward under first principles. Our federal system gives States “plenary authority to decide whether their local courts will have subject-matter jurisdiction over federal causes of action.” Haywood v. Drown, 556
U. S. 729, 743 (2009) (THOMAS, J., dissenting). The Constitution allows States to hear federal claims in their courts, but it does “not impose a duty on state courts to do so.” Id., at 747. Thus, “[o]nce a State exercises its sovereign prerogative to deprive its courts of subject-matter jurisdiction over a federal cause of action, it is the end of the matter as far as the Constitution is concerned.” Id., at 749.
The only potential constraint that the Constitution places on a State‘s jurisdictional discretion is the possibility that a federal statute may preempt state law. The Supremacy Clause makes the “Constitution, and the Laws of the United States which shall be made in Pursuance thereof . . . the supreme Law of the Land.”
We need not answer that question here because
This Court‘s precedents err to the extent they recognize a broader form of conflict preemption for “state-court procedural rules that are perceived to ‘burde[n] the exercise of the federal right’ in state court.” Haywood, 556 U. S., at 766 (THOMAS, J., dissenting) (quoting Felder, 487 U. S., at 141). This form of conflict preemption targets state-law rules that constitute an obstacle to the “goals” embodied in federal law. Id., at 138. But, only federal law itself can support preemption under the Supremacy Clause. Extratextual speculation about Congress‘s purposes cannot. See Wyeth v. Levine, 555 U. S. 555, 603-604 (2009) (THOMAS, J., concurring in judgment).
Our precedents also err in establishing the requirement at issue here—that state jurisdictional rules be “neutral,” even in the absence of a directly conflicting federal law. See infra, at 5. The Supremacy Clause does not of its own force “constrai[n] the States’ authority to define the subject-matter jurisdiction of their own courts.” Haywood, 556 U. S., at 750 (THOMAS, J., dissenting). Rather, in making the Constitution and federal law supreme, “it provides only a rule of decision that the state court must follow if it adjudicates the claim.” Id., at 751. I would therefore disregard our further limitation as “demonstrably erroneous.” See Gamble v. United States, 587 U. S. 678, 717-718 (2019) (THOMAS, J., concurring).*
II
This Court should affirm even under existing precedents. Alabama‘s exhaustion requirement does not run afoul of the limitations that this Court has identified on a State‘s authority to restrict federal causes of action from proceeding in state court. Petitioners misread our precedents in arguing otherwise, and the majority‘s theory likewise cannot pass muster.
A
Although this Court has held that there are limits on a State‘s discretion in regulating state-court jurisdiction over federal causes of action, our precedents emphasize that state authority predominates. “The general rule ‘bottomed deeply in belief in the importance of state control of state judicial procedure, is that federal law takes the state courts as it finds them.” Howlett v. Rose, 496 U. S. 356, 372 (1990) (quoting H. Hart, The Relations Between State and Federal Law, 54 Colum. L. Rev. 489, 508 (1954)). Each State thus has “great latitude to establish the structure and jurisdiction of [its] own courts.” Howlett, 496 U. S., at 372. This
Social Welfare: The Emerging Legal Issues, 74 Yale L. J. 1245, 1255 (1965); C. Reich, The New Property, 73 Yale L. J. 733 (1964)). As Justice Black recognized at the time, it “strains credulity” as a textual matter “to say that the government‘s promise of charity to an individual is property” protected by the Fourteenth Amendment. 397 U. S., at 275 (dissenting opinion). Moreover, further examination may be required as to whether
latitude allows States to decide which federal claims their courts can hear. Ibid.
As relevant here, our precedents establish that States must exercise this jurisdictional latitude only through “neutral” rules that do not embody any “policy disagreement” with federal law. Haywood, 556 U. S., at 735-737. Based on this principle, we have identified two narrow exceptions to a State‘s ordinary discretion. First, a State may not refuse to hear a federal claim “solely because [it] is brought under a federal law.” McKnett v. St. Louis & San Francisco R. Co., 292 U. S. 230, 233–234 (1934). Second, a State may not deprive its courts of jurisdiction over a “disfavored” federal claim, even if it simultaneously denies jurisdiction to an “identical state claim,” where doing so would “undermine federal law.” Haywood, 556 U. S., at 737-739.
For good reason, no one suggests that the first exception applies. Alabama‘s exhaustion requirement by its terms does “not discriminate against rights arising under federal laws.” See McKnett, 292 U. S., at 234. Instead, it imposes a generally applicable exhaustion process “for the making of determinations with respect to claims for unemployment compensation benefits.”
The second exception does not apply either. Alabama‘s exhaustion requirement is nothing like the statute in Haywood that this Court viewed as “disfavor[ing]” federal law. 556 U. S., at 738. That statute deprived New York courts of jurisdiction over “damages suits filed by prisoners against state correction officers,” based on the State‘s belief that they were “by and large frivolous and vexatious.” Id., at 733 (discussing
correction officers from a subset of disfavored
Alabama‘s decision to create an exhaustion requirement for all unemployment-benefits-related claims does not embody any comparable policy judgment. Rather, this requirement, which has existed since 1939, is an ordinary jurisdictional rule reflecting the Alabama Department of Labor‘s comparative “competence over the subject matter” of unemployment benefits. Howlett, 496 U. S., at 381; see 1939 Ala. Acts no. 497, pp. 737–741. The exhaustion process serves all the useful functions that this Court has recognized: It allows the agency with subject-matter expertise to retain primary responsibility over the area; it avoids unnecessary litigation; and it creates a record in case judicial review is necessary. McCarthy v. Madigan, 503 U. S. 140, 145 (1992). In short, Alabama‘s exhaustion requirement is a procedural step that “promotes judicial efficiency,” ibid., in contrast to the statute in Haywood, which created a de facto “immunity” shielding a class of claims from judicial review, 556 U. S., at 742. We have no authority to interfere with Alabama‘s choice.
B
Petitioners try to evade Alabama‘s exhaustion requirement by arguing for a different exception. On their view, our decisions in Patsy v. Board of Regents of Fla., 457 U. S. 496 (1982), and Felder establish that States are categorically precluded from imposing exhaustion requirements in the
Patsy addressed whether federal courts can impose an exhaustion requirement for
congressional directive to do so. See 457 U. S., at 501. The Court held that they cannot, reasoning that federal courts may create exhaustion requirements only where doing so is consistent with congressional intent, because “Congress is vested with the power to prescribe the basic procedural scheme under which claims may be heard in federal courts.” Id., at 501-502, 516. That analysis has no relevance to the question here: whether States have authority “to establish the structure and jurisdiction of their own courts.” Howlett, 496 U. S., at 372.
Felder too is inapposite. That decision held that
Felder would remain inapposite even if it had involved a purportedly jurisdictional rule compelling dismissal without prejudice.
although Felder noted that the statute “impose[d] an exhaustion requirement,” it treated that fact as one of multiple “interrelated” factors that caused the Wisconsin statute to “burden”
C
The majority rules for petitioners on narrower grounds, but its holding is equally unpersuasive. The majority does not dispute that, as a general matter, Alabama is entitled to apply its exhaustion requirement to
1
“[T]his Court has almost unfailingly refused to consider any federal-law challenge to a state-court decision unless the federal claim ‘was either addressed by or properly presented to the state court that rendered the decision we have been asked to review.” Howell v. Mississippi, 543 U. S. 440, 443 (2005) (per curiam) (quoting Adams v. Robertson, 520 U. S. 83, 86 (1997) (per curiam)). In fact, the Court‘s
historical practice has generally been to treat this preservation requirement as jurisdictional, although our more recent cases have expressed uncertainty on this issue. Howell, 543 U. S., at 445-446. In view of petitioners’ preservation obligation, we should reject as forfeited their newfound theory of futility, which was neither presented nor addressed below.
Until seeking certiorari, petitioners litigated this case as a facial challenge, arguing solely that
Because petitioners raised only a facial challenge below, they cannot press an as-applied
There is no reason to treat this case as the “very rare exceptio[n]” in which petitioners’ forfeiture might be overlooked. Adams, 520 U. S., at 86 (internal quotation marks omitted). The majority, which ignores that petitioners needed to raise their as-applied objection specifically, certainly provides no justification. See ante, at 10. Instead,
its analysis only highlights why we should not decide petitioners’ as-applied challenge in the first instance.
The majority‘s futility theory depends on the assumption that petitioners will never have their day in court if we leave Alabama‘s exhaustion requirement intact. See ante, at 7. But, petitioners’ failure to raise their as-applied claim below means that we have no way of knowing whether this assumption is true. It may be the case that the exhaustion requirement here contains an implicit futility exception. Cf. Graysville v. Glenn, 46 So. 3d 925, 929 (Ala. 2010) (identifying futility as a “recognized exceptio[n]” to the “exhaustion-of-administrative-remedies doctrine” generally). Or, it may be the case that petitioners may obtain mandamus relief, as the dissent below suggested and the State underscored. See 387 So. 3d, at 146 (Cook, J., dissenting); Tr. of Oral Arg. 54–56. As a federal court assessing petitioners’ objection in the first instance, we have no way to assess the viability of these or any other mechanisms.
The majority‘s attempts to disregard this uncertainty are unpersuasive. The majority concludes that the uncertainty should count against the State, and expresses doubt about the availability of mandamus based on the Alabama Supreme Court‘s failure to address that form of relief. Ante, at 9. But, that court had no reason to opine on the alternative pathways available to petitioners, given that petitioners failed to raise an as-applied challenge. We should not reward petitioners for their own mistake. Likewise, the majority‘s assertion that mandamus would be irrelevant even if it were available is puzzling. Ante, at 9-10. If petitioners can secure completion of the exhaustion process through mandamus, then by definition they will not be in a “catch-22” that “prevents [them] from obtaining a merits resolution of their
2
In any event, petitioners’ as-applied challenge fails on the
merits. Unlike the New York statute in Haywood, Alabama‘s exhaustion requirement is not ““an immunity statute cloaked in jurisdictional garb.” Contra, ante, at 9 (quoting Haywood, 556 U. S., at 742).
Properly understood, Haywood directs our focus to the challenged statute‘s purpose. The Court there viewed the New York statute as an immunity statute because it was “designed to shield” correction officers from damages claims brought by prisoners, “[b]ased on the belief” that these claims tended to be “frivolous and vexatious.” Id., at 741–742. In other words, States cannot implicitly reject the supremacy of federal law by basing a jurisdictional limitation—even one that also applies to state claims—on “policy
A focus on statutory purpose makes clear that Alabama‘s exhaustion requirement raises no Haywood problem. There is no credible argument that Alabama adopted its exhaustion requirement in order to defeat challenges to the exhaustion process itself. Alabama created its exhaustion scheme in 1939, decades before the understanding that public benefits give rise to a due process interest emerged. See supra, at 3-4, n. And, the Alabama exhaustion process is by all accounts an ordinary exhaustion requirement common among public-benefits schemes, which in the mine-run case serves to facilitate the adjudication of benefits determinations on the merits. There is no reason to think that Alabama intended to cause mischief in the rare context of a
At most, this case presents a circumstance in which Alabama‘s “neutral jurisdictional rule” has the effect of defeating a federal claim. See Haywood, 556 U. S., at 735. But, again, our precedents disallow a State‘s jurisdictional rule only if it is in fact not “neutral“—that is, if it is “based on a policy disagreement,” and so is intended to “shut the courthouse door to federal claims that it considers at odds with its local policy.” Id., at 737-738, 740.
The majority‘s contrary conclusion misunderstands Haywood. Ignoring that decision‘s purpose-focused language, the majority asserts that it disallows any state rule that “operates as an ‘immunity statute’ . . . by wholly barring a ‘particular species’ of
The majority also does not grapple with the possible ripple effects of its reading of Haywood. It professes only that its opinion is “narrow” and does nothing more than “resolv[e] this dispute.” Ante, at 10. But, the majority‘s protestations do not make it so.
A constraint based on incidental effects is notably more amorphous than our prior focus on statutory purpose. After all, to the extent the Supremacy Clause bars States from enacting nominally jurisdictional rules that “registe[r their] dissent” from federal policy, States may craft their laws with an eye toward avoiding conflict. Haywood, 556 U. S., at 737-738. But, the same is not true for incidental effects. No statute can be perfectly drafted to anticipate every application that ultimately arises, so it is inevitable that exhaustion requirements will occasionally slow or defeat claims that we might think, as a policy matter, ought to go forward. That happenstance is not a reason for suspicion, just as we do not malign the many federal statutes with similarly categorical exhaustion requirements. See, e.g., Booth v. Churner, 532 U. S. 731, 733–734 (2001) (applying
the Prison Litigation Reform Act‘s exhaustion requirement even where the exhaustion process could not provide the prisoner‘s requested relief). Here too, the Court should not encroach on Alabama‘s “latitude to establish the structure
III
The Court‘s decision is irreconcilable with both first principles and precedent. I respectfully dissent.