Haywood v. Drown

Summary

The Court held that New York violated the Supremacy Clause by denying its courts jurisdiction over damages actions under 42 U.S.C. § 1983 against correction officers while permitting those courts to hear analogous federal claims. Equal treatment of state and federal claims did not make the jurisdictional rule neutral because the statute was designed to shield a particular class of defendants from federally authorized liability. The judgment dismissing the actions was reversed and the case was remanded.