The U.S. Supreme Court case Keith Haywood v. Curtis Drown, et al., 2008 revolved around the issue of whether New York's Correction Law §24 was constitutional or not. This law barred state courts from hearing lawsuits filed by inmates against correctional facility employees for damages related to their employment, directing them instead to federal court under Section 1983 claims. The plaintiff, Keith Haywood, an inmate in a New York prison who had been assaulted by other prisoners and claimed that two corrections officers failed to protect him, challenged this law as unconstitutional because it violated his right of access to the courts. In a decision delivered by Justice Thomas on May 26th, 2009 (the case was argued in December of the previous year), the Supreme Court upheld Correction Law §24 with a majority vote of five justices against four dissenting ones. The court ruled that states have sovereign immunity which allows them discretion over how they structure their judicial systems and handle certain types of cases; therefore they can choose not to hear these kinds of suits without violating any constitutional rights.

In the dissenting opinion for Keith Haywood v. Curtis Drown, et al., Justice John Paul Stevens argued that the majority's decision was a departure from established precedent regarding Congress' power under Section 5 of the Fourteenth Amendment. He contended that New York’s Correction Law §24, which bars state courts from hearing suits brought by prisoners against correctional officers for damages related to their service, violated inmates’ constitutional rights and should be struck down as unconstitutional. The law effectively immunized correctional officers from being held accountable in state court for violating federal civil rights laws. This immunity contradicted previous rulings where similar immunities were found unconstitutional because they denied individuals a remedy for violations of their constitutional rights. Furthermore, he disagreed with the majority's interpretation of Congressional intent behind enacting such legislation and believed it did not intend to allow states to deny any judicial forum for certain colorable federal claims.