In the case of Patsy v. Board of Regents of the State of Florida, 1981, Patsy brought a lawsuit against her employer, The Board of Regents for alleged sex discrimination under Title VII and Section 1983. She claimed that she was denied promotions and subjected to different terms and conditions than male employees due to her gender. However, before filing suit in federal court, she did not pursue available state administrative remedies as required by Florida law. The Supreme Court had to decide whether exhaustion of state administrative remedies is necessary before bringing a Section 1983 claim in federal court. The Supreme Court ruled in favor of Patsy stating that plaintiffs are not required to exhaust any state administrative remedies before bringing their claims under section 1983 directly into federal court. This decision emphasized Congress's intent for section 1983 to provide an independent avenue for protection from constitutional rights violations regardless if other means were provided by the states.

In the dissenting opinion for Patsy v. Board of Regents of the State of Florida, Justice Powell argued that requiring plaintiffs to exhaust state administrative remedies before bringing a claim under Section 1983 would not undermine its purpose or effectiveness. He believed this requirement could actually enhance federalism by giving states an opportunity to correct their own mistakes and reduce unnecessary federal court litigation. Furthermore, he pointed out that many other civil rights statutes require exhaustion of administrative remedies as a precondition to filing suit in federal court. Thus, it was reasonable and consistent with congressional intent to interpret Section 1983 similarly. Justice Powell also expressed concern about the majority's reliance on legislative history rather than statutory text in interpreting Congress' intent regarding exhaustion requirements under Section 1983.