Janus v. American Federation of State, County, and Municipal Employees, Council 31
United States Court of Appeals for the Seventh Circuit · 2018 · Constitutional Law
Constitutional LawFirst AmendmentCivil ProcedureClaim PreclusionStandingPublic-Sector Union FeesAboodfair share fees
Facts
Illinois law permits a union representing public employees to collect dues from members and "fair share" fees from nonmembers for collective bargaining and contract administration. Governor Rauner sued to stop collection of those fees on First Amendment grounds, but his complaint was dismissed for lack of standing. Janus and Trygg, both public employees subject to union representation, sought to pursue the same constitutional challenge and asked that Abood be overruled. Trygg had previously litigated under Illinois law for the right, based on religious objection, to pay an equivalent amount to charity rather than to the union, and he obtained that relief.
Issue
Whether Janus and Trygg could maintain a First Amendment challenge to Illinois's fair-share fee scheme in the lower federal courts. More specifically, whether Trygg's claim was barred by claim preclusion and whether Janus stated a valid claim given Abood's controlling force.
Rule
A federal court must give a state-court judgment the same preclusive effect it would receive under state law, and a claim is barred when it arises from the same facts as prior litigation and the party had a full and fair opportunity to raise it there. In addition, lower federal courts cannot overrule controlling Supreme Court precedent, so a claim foreclosed by such precedent fails to state a valid claim in those courts.
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One of 10 multiple-choice questions for this case. Pick an answer to see why.
Leah Moreno, a public librarian in Columbus, Ohio, previously challenged a state labor statute before an Ohio administrative board, arguing that the statute entitled her to pay an equivalent amount to charity because of her religious objections. She won that statutory claim on judicial review in Ohio court. A year later, she files a federal suit alleging that the same statute violates the First Amendment because it compels support for union bargaining she opposes.
Is Leah's federal constitutional claim most likely barred?
Explanation. A federal court must give a state-court judgment the same preclusive effect it would receive under state law. A later claim is barred when it arises from the same facts as the earlier litigation and the party had a full and fair opportunity to raise it there. Here, both suits stem from the same law requiring payments tied to union representation, so the later First Amendment claim is precluded if it could have been raised on review. (Derived from Janus v. American Federation of State, County, and Municipal Employees, Council 31 (2018).)