In the Supreme Court of the United States
___________
MIRACLE STAR WOMEN’S RECOVERING COMMUNITY, INC.,
Petitioner,
v.
KATHERINE JETT, IN HER OFFICIAL CAPACITY, AND THE CALIFORNIA STATE HEALTH AND HUMAN SERVICES DEPARTMENT OF ALCOHOL AND DRUG PROGRAMS,
Respondent.
___________
On Petition for Writ of Certiorari to the
Court of Appeal of the State of California
for the Second Appellate District
This Court has repeatedly admonished that when state courts address federal claims under 42 U.S.C. § 1983, they cannot change the remedial scheme that Congress has provided. Testa v. Katt, 330 U.S. 386, 391 (1947). Part of the Section 1983 remedial scheme is compensatory damages, which includes an award of money. Carey v. Piphus, 435 U.S. 247, 256 (1978). Despite the clarity of federal law in this area, the California Court of Appeals overturned a jury verdict awarding petitioner close to $400,000 in compensatory damages for the state’s infringement of petitioner’s federal right to due process. In doing so, the court below held that monetary damages are unavailable when state officials violate the federal rights of its citizens.
The state court’s rule is unique in several respects: it conflicts with the purpose of 42 U.S.C. § 1983; it is contrary to several of this Court’s decisions; it deprives millions of California citizens a state court forum to litigate abuses of their federal rights; it grants immunity to state officials where none exists; and it will drive Section 1983 claims to overburdened federal district courts.
The question presented is:
Whether a state court, addressing a 42 U.S.C. § 1983 claim, can prohibit an award of compensatory money damages without violating the Supremacy Clause.
Conflict is not the right word, but it is the first one that comes to mind.
The California Court of Appeal’s decision is in significant conflict with the purpose of 42 U.S.C. § 1983 and several of this Court’s decisions. If the decision was not so far reaching, it could be tolerable; unfortunately, it affects the federal rights of millions. If the decision stands, other states will also immunize state officials from monetary damages when those officials abuse the federal rights of their citizens, and the deterrent for violating federal rights that monetary damages provide will vanish. If that is not bad enough, the lower court decision threatens to inundate overburdened federal district courts with § 1983 suits—because why would anyone file a § 1983 action in state court if those courts have taken monetary damages off the table. For these reasons, the Court’s review is warranted.
I. THE CALIFORNIA COURT OF APPEAL’S DECISION PROHIBITING COMPENSATORY DAMAGES FOR A FEDERAL CONSTITUTIONAL VIOLATION IS AN AFFRONT TO FEDERAL LAW AND THIS COURT’S DECISIONS, AND CONTRAVENES THE SUPREMACY CLAUSE.
Finally, by removing monetary damages from the compensation equation of § 1983, the state court has removed, from civil rights victims, the right to choice of forum. As noted above, state and federal courts have concurrent jurisdiction over § 1983 claims. Allen, 449 U.S. at 99. Concurrent jurisdiction, of course, affords litigants a valuable choice of forum to file their claim. But that choice is largely foregone if monetary damages are unavailable in one forum but not another.
There is no tension between the state court rule here and this Court’s decisions; that rope has been broken. Only this Court can tie the pieces back together by placing civil rights victims in the same position they would occupy without the state’s conflicting rule.
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