The U.S. Supreme Court recently agreed to hear a case to determine whether plaintiffs must pursue all available state administrative remedies before filing a federal lawsuit under Section 1983, which prevents entities from denying U.S. citizens their constitutional rights.
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Alabama Court Dismissed Case
The case, Williams v. Washington, stems from a decision in the Supreme Court of Alabama, which held that individuals who filed unemployment compensation claims with the Alabama Department of Labor should have first exhausted all legal remedies available through that agency before filing a federal civil rights violation claim.
In June 2023, the Alabama Supreme Court found that it lacked jurisdiction over the claim. It said the plaintiffs could not compel state courts to adjudicate federal claims that lie outside the state courts’ jurisdiction.
(Jurist)
Delays in Benefit Decisions
The plaintiffs claimed they faced excessive delays in getting unemployment benefits during the COVID-19 pandemic, and many who were denied early on never were able to schedule a hearing for an appeal.
From April 1, 2020, to March 14, 2022, the Alabama Department of Labor received almost 1.5 million unemployment claims, over 1 million of which were COVID-related, according to court documents. The state identified a significant backlog in appeal requests in its report to the U.S. Department of Labor in 2022, saying it had gotten but not addressed at least 82,000 appeals due to technological issues and staffing shortages.
A resident who believes that the Alabama Department of Labor unreasonably delayed processing an unemployment benefits claim may demand a court order compelling a prompt determination, according to court documents.
Legal Precedent
The plaintiffs contended that exhaustion of state administrative remedies is not required for a federal lawsuit in this context, and that the Alabama Supreme Court’s decision to the contrary conflicts with decisions of the U.S. Supreme Court and other state high courts.
Steve Marshall, Alabama’s attorney general, argued that it’s wrong to conclude that legal precedent under Patsy v. Board of Regents of the State of Florida categorically rejects any state-law administrative exhaustion requirement for Section 1983 claims.
Benefits Eligibility
Individual state laws vary, but there are some generalities that can help employers predict whether a terminated employee will qualify for unemployment benefits.
Workers who stop coming to work and violate an employer's call-in or attendance policy with no excusable reason typically will not get unemployment benefits. However, individuals who are terminated under an employer’s attendance policies after exhausting job-protected leave for medical reasons may be eligible for benefits.
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