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University of Tennessee v. Elliott

Supreme Court of the United States · 1986 · Civil Procedure

Civil ProcedurePreclusionTitle VIISection 1983issue preclusioncollateral estoppeladministrative preclusionTitle VII

Facts

The University sought to discharge respondent, a black employee, for inadequate work performance and misconduct. Respondent requested a hearing under Tennessee's administrative procedures act and also filed a federal suit alleging that the proposed discharge was racially motivated and violated Title VII and other civil rights laws. At the administrative hearing, the ALJ said he lacked jurisdiction over the federal civil rights claims but allowed respondent to present racial prejudice as an affirmative defense to the discharge charges. After extensive proceedings, the ALJ found some charges proved, found they were not racially motivated, ordered transfer rather than discharge, and that ruling was affirmed within the University; respondent did not seek state-court review.

Issue

Whether unreviewed factual findings made by a state administrative tribunal are entitled to preclusive effect in federal court when the plaintiff later brings discrimination claims under Title VII and under the Constitution and Reconstruction civil rights statutes, including § 1983.

Rule

28 U.S.C. § 1738 does not apply to unreviewed state administrative factfinding. As a matter of federal common law, Congress did not intend unreviewed state administrative proceedings to have preclusive effect on Title VII claims. But when a state agency, acting in a judicial capacity, resolves disputed issues of fact properly before it and the parties have had an adequate opportunity to litigate, federal courts must give the agency's factfinding in later actions under the Constitution and Reconstruction civil rights statutes the same preclusive effect it would receive in the State's courts.

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One of 10 multiple-choice questions for this case. Pick an answer to see why.

Nina Patel, a city engineer in Columbus, Ohio, was demoted after a state personnel board held a trial-type hearing with witnesses and exhibits and found the demotion was based on repeated safety violations rather than sex discrimination. Nina did not seek review in Ohio court and instead filed a federal suit alleging only a Title VII violation.

What effect should the federal court give the board's unreviewed factual finding on Nina's Title VII claim?

Explanation. The majority held that unreviewed state administrative findings do not preclude a federal Title VII action. Section 1738 applies to state-court judgments, not unreviewed administrative determinations, and Congress intended Title VII plaintiffs to receive a trial de novo notwithstanding such agency rulings. (Derived from University of Tennessee v. Elliott (n.d.).)