No. 23-191October Term 2024Decided Feb 21, 2025
Nancy Williams, et al., Petitioners v. Greg Reed, Secretary, Alabama Department of Workforce
The Supreme Court ruled that Alabama cannot require plaintiffs to exhaust state administrative remedies before filing a Section 1983 civil rights lawsuit in state court when doing so would effectively immunize officials from liability for administrative delays.
Case status
- Current stage
- Decided
- Latest event
- Decision released Feb 21, 2025
- What it's about
The Supreme Court ruled that Alabama cannot require plaintiffs to exhaust state administrative remedies before filing a Section 1983 civil rights lawsuit in state court when doing so would effectively immunize officials from liability for administrative delays. The Court held that such state exhaustion rules are preempted by federal law because they create procedural barriers that nullify federally guaranteed rights.
Question presented
Does a Section 1983 claim brought in state court require the plaintiffs to first exhaust state administrative remedies?
- Case path
Supreme Court of Alabama / Decision released Feb 21, 2025
- Area
Civil Rights
Documents
Related cases




Grounding
- Grounding
- Primary-source trail available.
- Note
- Plain-English explainer. Official filings and opinions remain authoritative.
- Checked
- Mar 30, 2026
- Method
- Methodology
Primary materials8
Supreme Court docket 23-191
docket | Mar 30, 2026
Primary case document
Supreme Court document | Mar 30, 2026
CourtListener docket record
docket | Mar 30, 2026
Questions Presented
brief | Mar 8, 2026
opinion
opinion | Feb 21, 2025
Reed
opinion | Feb 21, 2025
Oral Arguments - Reed
audio | Oct 7, 2024
Petition
brief | Aug 28, 2023