Felder v. Casey

487 U.S. 131, 108 S. Ct. 2302, 101 L. Ed. 2d 123, 1988 U.S. LEXIS 2867, 56 U.S.L.W. 4689
CourtSupreme Court of the United States
DecidedJune 22, 1988
Docket87-526
StatusPublished
Cited by1,108 cases

This text of 487 U.S. 131 (Felder v. Casey) is published on Counsel Stack Legal Research, covering Supreme Court of the United States primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Felder v. Casey, 487 U.S. 131, 108 S. Ct. 2302, 101 L. Ed. 2d 123, 1988 U.S. LEXIS 2867, 56 U.S.L.W. 4689 (1988).

Opinions

[134]*134Justice Brennan

delivered the opinion of the Court.

A Wisconsin statute provides that before suit may be brought in state court against a state or local governmental entity or officer, the plaintiff must notify the governmental defendant of the circumstances giving rise to the claim, the amount of the claim, and his or her intent to hold the named defendant liable. The statute further requires that, in order to afford the defendant an opportunity to consider the requested relief, the claimant must refrain from filing suit for 120 days after providing such notice. Failure to comply with these requirements constitutes grounds for dismissal of the action. In the present case, the Supreme Court of Wisconsin held that this notice-of-claim statute applies to federal civil rights actions brought in state court under 42 U. S. C. § 1983. Because we conclude that these requirements are pre-empted as inconsistent with federal law, we reverse.

W

On July 4, 1981, Milwaukee police officers stopped petitioner Bobby Felder for questioning while searching his neighborhood for an armed suspect. The interrogation proved to be hostile and apparently loud, attracting the attention of petitioner’s family and neighbors, who succeeded in convincing the police that petitioner was not the man they sought. According to police reports, the officers then directed petitioner to return home, but he continued to argue [135]*135and allegedly pushed one of them, thereby precipitating his arrest for disorderly conduct. Petitioner alleges that in the course of this arrest the officers beat him about the head and face with batons, dragged him across the ground, and threw him, partially unconscious, into the back of a paddy wagon face first, all in full view of his family and neighbors. Shortly afterwards, in response to complaints from these neighbors, a local city alderman and members of the Milwaukee Police Department arrived on the scene and began interviewing witnesses to the arrest. Three days later, the local alderman wrote directly to the chief of police requesting a full investigation into the incident. Petitioner, who is black, alleges that various members of the Police Department responded to this request by conspiring to cover up the misconduct of the arresting officers, all of whom are white. The Department took no disciplinary action against any of the officers, and the city attorney subsequently dropped the disorderly conduct charge against petitioner.

Nine months after the incident, petitioner filed this action in the Milwaukee County Circuit Court against the city of Milwaukee and certain of its police officers, alleging that the beating and arrest were unprovoked and racially motivated, and violated his rights under the Fourth and Fourteenth Amendments to the United States Constitution. He sought redress under 42 U. S. C. § 1983,1 as well as attorney’s fees pursuant to 42 U. S. C. § 1988. The officers moved to dis[136]*136miss the suit based on petitioner’s failure to comply with the State’s notice-of-claim statute. That statute provides that no action may be brought or maintained against any state governmental subdivision, agency, or officer unless the claimant either provides written notice of the claim within 120 days of the alleged injury, or demonstrates that the relevant subdivision, agency, or officer had actual notice of the claim and was not prejudiced by the lack of written notice. Wis. Stat. §893.80(l)(a) (1983 and Supp. 1987).2 The statute further provides that the party seeking redress must also [137]*137submit an itemized statement of the relief sought to the governmental subdivision or agency, which then has 120 days to grant or disallow the requested relief. §893.80(l)(b). Finally, claimants must bring suit within six months of receiving notice that their claim has been disallowed. Ibid.

The trial court granted the officers’ motion as to all state-law causes of action but denied the motion as to petitioner’s remaining federal claims. The Court of Appeals affirmed on the basis of its earlier decisions holding the notice-of-claim statute inapplicable to federal civil rights actions brought in state court. The Wisconsin Supreme Court, however, reversed. 139 Wis. 2d 614, 408 N. W. 2d 19 (1987). Passing on the question for the first time, the court reasoned that while Congress may establish the procedural framework under which claims are heard in federal courts, States retain the authority under the Constitution to prescribe the rules and procedures that govern actions in their own tribunals. Accordingly, a party who chooses to vindicate a congressionally created right in state court must abide by the State’s procedures. Requiring compliance with the notice-of-claim statute, the court determined, does not frustrate the remedial and deterrent purposes of the federal civil rights laws because the statute neither limits the amount a plaintiff may recover for violation of his or her civil rights, nor precludes the possibility of such recovery altogether. Rather, the court reasoned, the notice requirement advances the State’s legitimate interests in protecting against stale or fraudulent claims, facilitating prompt settlement of valid claims, and identifying and correcting inappropriate conduct by governmental employees and officials. Turning to the question of compliance in this case, the court concluded that the complaints lodged with the local police by petitioner’s neighbors and the letter submitted to the police chief by the local aider-man failed to satisfy the statute’s actual notice standard, because these communications neither recited the facts giving [138]*138rise to the alleged injuries nor revealed petitioner’s intent to hold the defendants responsible for those injuries.

We granted certiorari, 484 U. S. 942 (1987), and now reverse.

II

No one disputes the general and unassailable proposition relied upon by the Wisconsin Supreme Court below that States may establish the rules of procedure governing litigation in their own courts. By the same token, however, where state courts entertain a federally created cause of action, the “federal right cannot be defeated by the .forms of local practice.” Brown v. Western R. Co. of Alabama, 338 U. S. 294, 296 (1949). The question before us today, therefore, is essentially one of pre-emption: is the application of the State’s notice-of-claim provision to § 1983. actions brought in state courts consistent with the goals of the federal civil rights laws, or does the enforcement of such a requirement instead “‘stan[d] as an obstacle to the accomplishment and execution of the full purposes and objectives of Congress’”? Perez v. Campbell, 402 U. S. 637, 649 (1971) (quoting Hines v. Davidowitz, 312 U. S. 52, 67 (1941)).

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Bluebook (online)
487 U.S. 131, 108 S. Ct. 2302, 101 L. Ed. 2d 123, 1988 U.S. LEXIS 2867, 56 U.S.L.W. 4689, Counsel Stack Legal Research, https://law.counselstack.com/opinion/felder-v-casey-scotus-1988.