Disclaimer:
The case on which this summary is based may no longer be current law.
Also, if the case was decided on summary judgment, the court recited the
"facts" in the light most favorable to the non-movant, which may not be
the true facts.
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Former police officer's Title VII
action is barred by doctrine of res judicata where he could have pursued
this claim as part of an administrative appeal in state court concerning eligibility for duty-related disability benefits.
Garcia v. Village of Mount Prospect, 360 F.3d 630 (7th Cir. February 23,
2004) - This is a Title VII action. Jose Garcia, an Hispanic, was a police
officer for the Village. In April of 1998, he suffered a heart attack and
sought duty-related disability benefits from the Mount Prospect Police
Pension Board. Prior to his heart attack, Garcia had given a deposition in
the employment discrimination lawsuit of an Hispanic former police trainee.
During his deposition, Garcia testified about various discriminatory
practices engaged in by members of the police department -- including Sgt.
George Steiner. Steiner was a member of the Police Pension Board. The Board
awarded Garcia non-duty-related disability benefits -- which is a lower
amount of benefits than duty-related benefits. Garcia sought administrative
review of this decision in the Cook County Circuit Court. Although Garcia
argued that the decision was arbitrary and capricious, he never argued that
the Board's decision was due to discrimination or retaliation. The state
court judge affirmed the Board's decision to award non-duty-related
benefits. During the pendency of this administrative appeal, Garcia filed an
EEOC charge alleging that he was denied duty-related benefits based upon
discrimination and retaliation. The district court granted summary judgment
based on the Rooker-Feldman doctrine. The Seventh Circuit is not sure that
the Rooker-Feldman doctrine applies because under that doctrine the
complained-of injury must have been caused by the state-court judgment
itself. Instead, the Seventh Circuit holds that the defendants are entitled
to summary judgment based on the application of the doctrine of res
judicata. Under Illinois law, res judicata applies if the Circuit Court's
affirmance of the Board's decision: (1) was a final judgment on the merits;
(2) involved the same parties or their privies as the current claims; and
(3) constituted the same cause of action as the current claims. With respect
to the "same parties" issue, the Court finds that Sgt. George Steiner and
the Village are in privy with the Board (who was the defendant in the state
court action). With respect to the issue of whether the state court action
is the same cause of action as this one, Illinois follows a transactional
approach -- which means that this lawsuit and the administrative appeal
constitute the same cause of action if the claims arise from the same group
of operative facts even if there is not a substantial overlap of evidence.
The Court finds that this is the same cause of action. Therefore, the requirements for
res judicata have been met.
The remaining question is whether Garcia had a full and fair
opportunity to litigate his discrimination claims. The Court holds that he
did because he could have pursued those claims in his state court action.
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