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CIVIL RIGHTS-1983-DUE PROCESS-CLAIMS SYSTEM

Williams v. Reed, 2025 U.S. LEXIS 550, (U.S. Supreme Ct., February 21, 2025) (Kavanaugh, J.)

Several unemployed workers in Alabama applied for unemployment benefits from the State. In their view, the Alabama Department of Labor has unlawfully delayed the processing of their benefits claims. So, the claimants sued the Alabama Secretary of Labor in state court under 42 U. S. C. §1983, raising due process and federal statutory arguments and seeking a court order requiring the Department to process their claims more quickly. The Alabama Supreme Court ruled that the claimants could not sue under §1983 to challenge delays in the administrative process until the claimants completed that process. But that ruling created a catch-22: Because the claimants cannot sue until they complete the administrative process, they can never sue under §1983 to obtain an order expediting the administrative process. This Court’s precedents do not permit States to immunize state officials from §1983 suits in that way. See Haywood v. Drown, 556 U. S. 729, 129 S. Ct. 2108, 173 L. Ed. 2d 920 (2009); Howlett v. Rose, 496 U. S. 356, 110 S. Ct. 2430, 110 L. Ed. 2d 332 (1990). On that narrow ground, we reverse.