The Supreme Court has held that decisions, findings and rulings of a state or local agency may not collaterally estop either discrimination claims under Title VII, Univ. of Tennessee v. Elliott, 478 U.S. 788 (1986), or of age discrimination under the ADEA. Astoria Fed. Sav. & Loan Assn. v. Solimino, 501 U.S. 104 (1991). And neither do state or local agency rulings or findings collaterally estop claims under the Americans With Disabilities Act (ADA), the Sixth Circuit ruled recently in Smith v. Perkins Board of Education, No 12-3187 (February 27, 2013).
Carol Ann Smith was an experienced teacher with a severe case of Type 2 diabetes. Her condition deteriorated to the point that she was accused of sleeping in class and other deficiencies, all of which had to do with her diabetes she claimed. Nevertheless, her school board terminated her employment, and her termination was upheld by an administrative hearing officer, who found that Smith's termination was supported by "good cause" - her falling asleep in class.
Smith did not appeal the hearing officer's decision, although she could have. Instead, she filed suit alleging, among other things, that her termination violated the ADA. The district court granted summary judgment to the school board on Smith's ADA claim (and all her other claims too), ruling that she was collaterally estopped by the hearing officer's "good cause" finding from contesting her termination by way of her ADA claim.
The Sixth Circuit reversed, holding that "collateral estoppel principles do not apply to claims brought under the ADA because Congress has demonstrated its intent that unreviewed state administrative findings not have preclusive effect in this statutory context." "The analysis," the court continued, "was straightforward because the ADA explicitly incorporates all of the enforcement powers, remedies, and procedures of Title VII." Since state agency decisions do not support collateral estoppel against Title VII claims, neither can it apply to ADA claims, the court concluded.
