NANCY WILLIAMS, ET AL., PETITIONERS v. GREG REED, SECRETARY, ALABAMA DEPARTMENT OF WORKFORCE, 604 U.S. 168

Summary

HOLDINGS: [1]-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 42 U.S.C.S. § 1983 due process suits alleging that the Department had unlawfully delayed in processing benefits claims. By affording immunity from those claims, the Alabama ruling contravened § 1983 precedents. Where a state court’s application of a state exhaustion requirement in effect immunized state officials from § 1983 claims challenging delays in the administrative process, state courts were not allowed to deny those § 1983 claims on failure-to-exhaust grounds.