Key Points

  • The Alabama Supreme Court dismissed the claimants' appeal and left in place a circuit court order finding their Section 1983 action moot.
  • The claimants conceded that their claims over delays in processing unemployment applications are moot, not disputing that there is no likelihood of a repeat of the 2020 and 2021 delays.
  • The court read Williams v. Reed as limited to Section 1983 delay claims and said it did not address the claimants' separate claim about the clarity of the department's notices.
  • The court held the claimants failed to show that any remedy remains on the notice claim, finding their cursory reliance on Social Security Act review cases to seek reopening of closed applications inadequate.
  • The court expressed no opinion on the broader issues raised by the notice claim.

The Alabama Supreme Court on Friday dismissed an appeal by unemployment claimants who won a reversal at the U.S. Supreme Court last year, holding that their challenge to the state's handling of jobless-benefit claims during the COVID-19 pandemic is moot, meaning a ruling could no longer give them any effective relief.

Justice Bryan wrote for the court, joined by Chief Justice Stewart and Justices Shaw, Sellers, Mendheim, Cook and McCool. Justices Wise and Parker recused. The dismissal leaves in place an October 2025 order of the Montgomery Circuit Court, which found that every claimant had either been paid in full or received a final administrative decision.

The ruling ends a case that produced Williams v. Reed, the 2025 decision in which the U.S. Supreme Court barred Alabama's courts from using an exhaustion rule to throw out Section 1983 claims over administrative delay. The Alabama court read Williams as confined to those delay claims, and it held that the claimants had not shown that any remedy remained for a separate claim attacking the clarity of the state's benefit notices.

The claimants sued in September 2022 in Montgomery Circuit Court, naming what was then the Alabama Department of Labor, now the Alabama Department of Workforce, and its secretary. An amended complaint dropped the department, leaving Secretary Greg Reed as the sole defendant in his official capacity. Every claim arose under 42 U.S.C. § 1983. The claimants alleged that the secretary's handling of their applications violated the Social Security Act and the Fourteenth Amendment's Due Process Clause.

The complaint sought injunctions and attorney fees. Most of the requested injunctions would have required the secretary to process applications promptly, as applications surged with the onset of the COVID-19 pandemic. Two requests concerned the department's notices. The claimants asked for an order requiring the secretary to provide "all notices to claimants using language and format making them easily read and understood by people with an eighth[-]grade education."

The circuit court dismissed the suit. In June 2023 the Alabama Supreme Court affirmed, holding that the circuit court lacked jurisdiction because the claimants had not exhausted the state's administrative review process for unemployment claims. The U.S. Supreme Court reversed on what it called a "narrow ground." It held that state courts "may not deny those § 1983 claims on failure-to-exhaust grounds" when a state court's application of a state exhaustion requirement "in effect immunizes state officials from § 1983 claims challenging delays in the administrative process."

Back in Alabama, the secretary told the state high court that the claimants had "all either been paid in full or received administratively final denials." The claimants disputed that account. In September 2025 the court sent the case to the circuit court to resolve the factual dispute. After written submissions and a hearing with oral argument and testimony from one witness, the circuit court found that the claimants "have either been paid in full or received administratively final determinations on their claims for unemployment benefits."

When the case returned to the state Supreme Court, the claimants conceded the delay claims. Their brief said that "with the ending of the COVID-19 emergency, things have changed, and there is no likelihood of a repeat of the delays that claimants suffered from in 2020 and 2021." Justice Bryan concluded that "it appears undisputed that the delay claims have become moot."

The claimants argued instead that at least several of them still had "live claims" based on the deprivation of due-process notice. Their brief focused on three claimants and called the notice claim a "different matter" from the delay claims. Justice Bryan wrote that the argument "highlights the fact that the United States Supreme Court's decision in Williams did not address any separate notice claim asserted by the plaintiffs."

The court then ordered the parties to show cause on how Williams bore on the notice claim. In response, the claimants called the two sets of claims "intertwined" and argued that Williams "applies with identical force to confusing notices." Justice Bryan wrote in a footnote that the court "cannot logically adopt both of the plaintiffs' inconsistent positions," and the court treated the claimants as keeping their original view that the notice claim survived.

As a remedy for the allegedly deficient notices, the claimants asked that the secretary be required to reopen their closed applications. They relied mainly on two federal appeals court decisions, Day v. Shalala from the Sixth Circuit and Gonzalez v. Sullivan from the Ninth Circuit. The court noted that both were Social Security disability cases, not Section 1983 suits, in which claimants sought federal-court review of decisions declining to reopen their benefit claims under that act's separate review procedure.

"Strikingly, given the history of this case, the plaintiffs entirely ignore the fact that the federal statutory scheme at issue in cases like Day and Gonzalez entails its own jurisdictional and administrative-exhaustion considerations," Justice Bryan wrote. Justice Bryan added that the claimants' "cursory citations to Day and Gonzalez fall woefully short" of showing that the court should order the secretary to reopen their applications.

The court also noted that the claimants had not argued for treating the notice claim as a request under Alabama law for review of a refusal to reopen. They had not asserted that the secretary ever made such a decision on any of their applications. "In short, the plaintiffs have not connected the necessary dots to warrant the relief they now appear to seek, and it is not this Court's function to do so for them," Justice Bryan wrote.

The court limited the reach of its holding. It was careful to "express no opinion concerning the multifaceted issues raised by the plaintiffs' limited argument in this Court regarding their notice claim." It had "no difficulty in concluding that the plaintiffs have failed to adequately demonstrate that a remedy still exists for their notice claim," and so the claimants had not shown that the circuit court erred.

The court dismissed the appeal. The circuit court's October 23, 2025, order declaring the action moot remains in effect. The opinion is subject to formal revision before publication in the Southern Reporter.