In Felder v. Casey, 487 U.S. 131 (1988), an arrestee allegedly beaten during the course of his arrest by police officers employed by the City of Milwaukee failed to meet the requirements of the Wisconsin notice of claim statute in bringing his State court action against the City and certain of the arresting officers under 42 USC 1983. The Supreme Court held that the Supremacy Clause preempted the Wisconsin notice of claim requirement in a section 1983 action brought in State court. The United States Supreme Court stated that, "Although it is true that the principal remedy Congress chose to provide injured persons was immediate access to federal courts, it did not leave the protection of such rights exclusively in the hands of the federal judiciary, and instead conferred concurrent jurisdiction on state courts as well." (Felder, supra, at p. 147.) The Felder court reiterated that civil rights actions "'exist independent of any other legal or administrative relief that may be available as a matter of federal or state law. They are judicially enforceable in the first instance.'" (Felder, supra, at p. 148.)