In Patsy v. Florida Board of Regents (1982) 457 U.S. 496, the United States Supreme Court held, based on section 1983's legislative history, that "exhaustion of state administrative remedies should not be required as a prerequisite to bringing an action pursuant to section 1983." (Patsy, supra, at p. 516.) The court also rejected policy arguments for imposing an exhaustion requirement: "Policy considerations alone cannot justify judicially imposed exhaustion unless exhaustion is consistent with congressional intent. . . . The relevant policy considerations do not invariably point in one direction, and there is vehement disagreement over the validity of the assumptions underlying many of them. The very difficulty of these policy considerations, and Congress' superior institutional competence to pursue this debate, suggest that legislative not judicial solutions are preferable." (Id., at p. 513.)