Enrico Mangiafico v. Town of Farmington

Summary

The court held that a plaintiff bringing a claim under 42 U.S.C. § 1983 in state court need not exhaust state administrative remedies, regardless of whether the plaintiff seeks damages, injunctive relief, or other relief. It overruled the Connecticut precedent that had treated exhaustion as a jurisdictional prerequisite for § 1983 claims seeking injunctive relief and held that the inadequacy of a legal remedy is an element of an injunction claim, not a jurisdictional requirement. The court also held that the defendants' alternative ripeness defense was prudential rather than jurisdictional and had not been preserved because it was raised for the first time on appeal.