Williams v. Reed
 | |
| Williams v. Reed | |
| Term: 2024 | |
| Important Dates | |
| Argued: October 7, 2024 Decided: February 21, 2025 | |
| Outcome | |
| reversed and remanded | |
| Vote | |
| 5-4 | |
| Majority | |
| Brett Kavanaugh • Chief Justice John Roberts • Sonia Sotomayor • Elena Kagan • Ketanji Brown Jackson | |
| Dissenting | |
| Clarence Thomas • Samuel Alito • Neil Gorsuch • Amy Coney Barrett | |
- This article is about the court case previously known as Williams v. Washington; it became Williams v. Reed when Greg Reed became the secretary of workforce for Alabama.
Williams v. Reed is a case challenging whether plaintiffs must pursue all state administrative remedies before being authorized to file a claim in court. The case was decided before the Supreme Court of the United States on February 21, 2025. The case was argued on October 7, 2024, during the court's October 2024-2025 term.
In a 5-4 decision, the U.S. Supreme Court reversed the Supreme Court of Alabama's ruling and remanded the case for further proceedings, holding that state courts cannot require plaintiffs to complete all state administrative processes before filing a lawsuit if those delays are the basis of the legal challenge. The decision clarifies the role of courts in reviewing administrative delays and limits procedural requirements that could prevent timely legal review. Justice Brett Kavanaugh wrote the majority opinion. Justice Clarence Thomas filed a dissenting opinion, joined by Justices Samuel Alito, Neil Gorsuch, and Amy Coney Barrett as to Part II.[1]
The case came on a writ of certiorari to the Supreme Court of Alabama. To review the lower court's opinion, click here.
Why it matters: This case clarifies that plaintiffs are not required to exhaust state administrative remedies before filing a civil rights claim in court if those delays are the basis of the legal challenge. This decision reinforces the precedent set in Patsy v. Board of Regents (1982) and confirms that its protections extend to both state and federal courts. By limiting procedural barriers that could delay or prevent timely legal review, the ruling strengthens access to the courts for individuals challenging administrative actions on civil rights grounds.
Background
| Administrative State |
|---|
|
| Five Pillars of the Administrative State |
| • Judicial deference • Nondelegation • Executive control • Procedural rights • Agency dynamics |
| Click here for more coverage of the administrative state on Ballotpedia |
Case summary
The following are the parties to this case:[3]
- Petitioner: Nancy Williams, et al.
- Legal counsel: Adam G. Unikowsky (Jenner & Block LLP)
- Respondent: Fitzgerald Washington, Alabama Commissioner of Labor
- Legal counsel: Edmund Gerard LaCour Jr. (Office of the Alabama Attorney General)
The following summary of the case was published by Oyez, a free law project from Cornell’s Legal Information Institute, Justia, and the Chicago-Kent College of Law:[4]
| “ |
Dissatisfied with the Alabama Department of Labor’s handling of their unemployment benefits applications, 26 plaintiffs filed a complaint and motion for injunctive relief against Secretary Fitzgerald Washington and the Department. The plaintiffs, each having filed applications for benefits, alleged various grievances against the Department’s processing methods. Subsequently, Secretary Washington and the Department filed a motion to dismiss the complaint. In response, the plaintiffs amended their complaint, which resulted in the omission of several initial claims and the exclusion of the Department as a defendant. The remaining allegations in the suit were federal claims under 42 U.S.C. § 1983, accusing Secretary Washington of implementing policies and procedures that violated both the Social Security Act of 1935, 42 U.S.C. § 503(a)(1), and the Due Process Clause of the Fourteenth Amendment. The plaintiffs sought various forms of relief, including multiple permanent and preliminary injunctions to expedite the handling of unemployment compensation applications and improve communication clarity, as well as attorney fees. Secretary Washington again moved to dismiss the case, citing reasons such as lack of subject-matter jurisdiction, absence of a private cause of action, and the substantive meritlessness of the claims. The court granted the dismissal without stating the basis for it. The plaintiffs moved to alter, amend, or vacate the judgment, but the court denied their motion. They then appealed to the Alabama Supreme Court, which affirmed the dismissal, concluding that the lower court lacked jurisdiction over the suit because the plaintiffs had not yet exhausted mandatory administrative remedies.[5] |
” |
To learn more about this case, see the following:
Timeline
The following timeline details key events in this case:
- February 21, 2025: The U.S. Supreme Court reversed the Supreme Court of Alabama's ruling and remanded the case for further proceedings.
- October 7, 2024: The U.S. Supreme Court heard oral argument.
- January 12, 2024: The U.S. Supreme Court agreed to hear the case. When the case was originally accepted by the U.S. Supreme Court, the case name was Williams v. Washington.
- August 28, 2023: Nancy Williams, Aaron Johnson, Derek Bateman, Dashonda Bennett, Latisha Kali, Quinton Lee, Esta Glass, Joyce Jones, Deja Bush, Jarvis Dean, Taja Penn, Lisa Cormier, Tammy Cowart, John Young, Latara Jackson, Senata Waters, Raymond Williams, Crystal Harris, Rashunda Williams, Mark Johnson, Mia Brand, and Cynthia Hawkins appealed to the U.S. Supreme Court.
- June 30, 2023: The Supreme Court of Alabama affirmed the decision of the Circuit Court of Montgomery County.
Questions presented
The petitioner presented the following questions to the court:[2]
Questions presented:
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Oral argument
The U.S. Supreme Court heard oral argument on October 7, 2024.
Audio
Audio of oral argument:[6]
Transcript
Transcript of oral argument:[7]
Outcome
In a 5-4 decision, the U.S. Supreme Court reversed the Supreme Court of Alabama's ruling and remanded the case for further proceedings, holding that state courts cannot require plaintiffs to complete all state administrative processes before filing a lawsuit if those delays are the basis of the legal challenge. The decision clarifies the role of courts in reviewing administrative delays and limits procedural requirements that could prevent timely legal review. Justice Brett Kavanaugh wrote the majority opinion. Justice Clarence Thomas filed a dissenting opinion, joined by Justices Samuel Alito, Neil Gorsuch, and Amy Coney Barrett as to Part II.[1]
Opinion
In the court's majority opinion, Justice Brett Kavanaugh wrote:[1]
| “ |
Alabama’s exhaustion requirement operates to immunize state officials from a narrow class of claims brought under §1983—namely, claims of unlawful delay in the administrative process. Under Alabama’s exhaustion requirement, state courts cannot review claims of unlawful delays under §1983 unless and until the claimants first complete the administrative process and receive a final decision on their claims. In essence, Alabama has said that to challenge delays in the administrative process under §1983, you first have to exhaust the administrative process. Of course, that means that you can never challenge delays in the administrative process. That catch-22 prevents the claimants here from obtaining a merits resolution of their §1983 claims in state court and in effect immunizes state officials from those kinds of §1983 suits for injunctive relief.
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 §1983 due process suits alleging that the Department has unlawfully delayed in processing benefits claims. By affording immunity from those claims, the Alabama ruling contravenes this Court’s §1983 precedents. We therefore reverse the judgment of the Alabama Supreme Court and remand the case for further proceedings not inconsistent with this opinion. [5] |
” |
| —Justice Brett Kavanaugh | ||
Dissenting opinion
Justice Clarence Thomas filed a dissenting opinion, which Justices Samuel Alito, Neil Gorsuch, and Amy Coney Barrett joined as to Part II.
In his dissent, Justice Thomas wrote:[1]
| “ |
Taken together, this case should begin and end with Alabama’s plenary authority to decide which federal matters its state courts will have subject-matter jurisdiction to hear. Alabama exercised that authority to create an exhaustion requirement, and we should respect its decision. [5] |
” |
| —Justice Clarence Thomas | ||
Text of the opinion
Read the full opinion here.
Arguments
Chamber of Commerce amici brief for reversal
The United States Chamber of Commerce submitted an amicus brief arguing for reversal in this case. The brief argued on the side of plaintiffs and for disallowing requirements to exhaust state administrative remedies before suing in state court. According to this brief, the Alabama Supreme Court decision:
| “ | would threaten to create serious obstacles to businesses and trade associations that seek to challenge state actions that violate both federal and state rights. States could frustrate the effective and efficient vindication of such rights by subjecting plaintiffs to burdensome administrative schemes.[8][5] | ” |
Tennessee and 15 other states amici brief against reversal
Tennessee and 15 other states submitted an amicus brief arguing against reversal in this case. The brief argued on the side of defendants and for allowing requirements to exhaust state administrative remedies before suing in state court. They argued that:
| “ | For the Court to reverse, it must ignore several core tenants of federalism. It must invent legislative powers neither possessed nor wielded by Congress, and it must contradict some our Constitution’s most celebrated expositors. See Ward, 51 Mass. (10 Metcalf) at 589 (citing Justice Story’s treatise and Chancellor Kent’s commentaries). And for what? If the Applicants here have colorable claims under the Civil Rights Act, they can take those claims to their local federal courthouse. They do not need a ruling from this Court telling their State how to distribute its own sovereign judicial power.[9][5] | ” |
October term 2024-2025
The Supreme Court began hearing cases for the term on October 7, 2024. The court's yearly term begins on the first Monday in October and lasts until the first Monday in October the following year. The court generally releases the majority of its decisions in mid-June.[10]
See also
External links
- Search Google News for this topic
- U.S. Supreme Court docket file - Williams v. Reed (petitions, motions, briefs, opinions, and attorneys)
- SCOTUSblog case file for Williams v. Reed
Footnotes
- ↑ 1.0 1.1 1.2 1.3 U.S. Supreme Court, Williams v. Reed, decided February 21, 2025
- ↑ 2.0 2.1 U.S. Supreme Court, "23-191 WILLIAMS V. WASHINGTON," accessed January 16, 2024
- ↑ Supreme Court of the United States, "No. 23-191," accessed August 7, 2024
- ↑ Oyez, "Williams v. Washington," accessed August 7, 2024
- ↑ 5.0 5.1 5.2 5.3 5.4 5.5 Note: This text is quoted verbatim from the original source. Any inconsistencies are attributable to the original source.
- ↑ Supreme Court of the United States, "Oral Argument - Audio," argued October 7, 2024
- ↑ Supreme Court of the United States, "Oral Argument - Transcript," argued October 7, 2024
- ↑ U.S. Chamber of Commerce, "Brief of Amicus Curiae the Chamber of Commerce of the United States in Support of Petitioners," April 18, 2024
- ↑ State of Tennessee, et. al., "Brief for the States of Tennessee, Idaho, Indiana, Iowa, Kansas, Louisiana, Mississippi, Nebraska, North Dakota, Ohio, South Carolina, South Dakota, Texas, Utah, and West Virginia, and the Commonwealth of Pennsylvania as Amici Curiae in Support of Respondent," July 2, 2024
- ↑ SupremeCourt.gov, "The Supreme Court at Work: The Term and Caseload," accessed January 24, 2022
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