Mangiafico v. Farmington

The Supreme Court held that, in light of Patsy v. Board of Regents, 457 U.S. 496, 501 (1982), and its progeny, a plaintiff is not required to exhaust administrative remedies prior to filing a 42 U.S.C. 1983 claim in state court, regardless of the type of relief sought, and therefore, this Court's holdings in Pet v. Department of Health Services, 542 A.2d 672 (1988), and Laurel Park, Inc. v. Pac, 485 A.2d 1272 (1984), that exhaustion of state administrative remedies is a jurisdictional prerequisite to the filing of a section 1983 action for injunctive relief are overruled.Plaintiff, a homeowner who was the subject of several enforcement action under a municipal blight ordinance, brought a claim alleging a deprivation of civil rights under 42 U.S.C. 1983. The trial court dismissed Plaintiff's section 1983 claims for lack of subject matter jurisdiction on the ground that Plaintiff had failed to exhaust his administrative remedies. The Appellate Court affirmed. The Supreme Court reversed with respect to Plaintiff's section 1983 claims, holding that Plaintiff was not required to exhaust his state administrative remedies prior to filing his section 1983 claims in state court. View "Mangiafico v. Farmington" on Justia Law