Isaac Mulamba v. Board of Education of Baltimore County
SocialSecurity DueProcess EmploymentDiscrimina JusticiabilityDoctri
Whether a state court's application of heightened pleading standards to federal Title VII claims, beyond those required under Federal Rule of Civil Procedure 8(a) and by this Court, violates the Supremacy Clause by undermining the uniform enforcement of federal civil rights and depriving plaintiffs of access to federal remedies based on forum selection
The supremacy of federal law and the Supreme Court’s authority in resolving conflicts between federal and state law are well established: e State courts are subject to the jurisdiction of the Supreme Court and _ federal government. See Chisholm v. Georgia, 2 U.S. 419 (1793). e “The Supremacy Clause demands that state law yield to federal law...The importance of the Supreme Court’s role as the final arbiter of federal constitutional questions requires that state courts adhere to this Court’s ruling[s].” Michigan uv. Long, 463 U.S. 1032, 1040-1041 (1983). The Appellate Court of Maryland, following binding state law and precedents, affirmed the Baltimore County Circuit Court’s application of heightened pleading standards, that required stating a prima facie case at the pleading stage and dismissed the pro se plaintiffs complaint for failure to state a claim. The question is: “Whether a state court's application of heightened pleading standards to federal Title VII claims, beyond those required under Federal Rule of Civil Procedure 8(a) and by this Court, violates the Supremacy Clause by undermining the uniform enforcement of federal civil rights and depriving plaintiffs of access to federal remedies based on forum selection.”