Brief Fact Summary.
A man who believes he was fires for discrimination brings his claim with the EEOC, a state agency, in state court, and then in federal court.
Synopsis of Rule of Law.
The decision of a state court upholding a state agency’s finding that a claim of employment discrimination is meritless has res judicata effect in federal court.
To meet this standard, state proceedings need do no more than satisfy the minimum procedural requirements of the Fourteenth Amendment's Due Process Clause.View Full Point of Law
Plaintiff Kremer, a Polish immigrant, was hired by Defendant in 1973 but terminated in 1975 with a few other employees. Kremer reapplied for the same position several times but was denied, despite other people that were also terminated regaining their employment. Kremer filed a discrimination charge with the Equal Employment Opportunity Commission alleging he was not rehired because of his religion and national origin. The EEOC referred Kremer’s complaint to the New York Division of Human Rights (NYDHR). NYDHR determined that there was no probable cause showing that Defendant Chemical discriminated against Kremer. NYDHR’s board of appeals affirmed the decision, finding that it was not arbitrary or capricious. Kremer refiled his complaint with the EEOC and petitioned the New York Supreme Court to set aside NYDHR’s finding. The New York Supreme Court affirmed and Kremer did not seek review by the Court of Appeals of New York. The EEOC also found no cause to believe Defendant Chemical discriminated against Kremer. Kremer brought suit against Defendant Chemical in federal district court alleging a violation of Title VII. The federal court dismissed the claim citing res judicata. Kremer appealed and the U.S. Supreme Court granted certiorari.
Is the decision of a state court upholding the decision of a state agency entitled to res judicata if the claimant brings the same claim in federal court?
Yes, the decision of a state court upholding the decision of a state agency is entitled to res judicata if the claimant brings the same claim in federal court. The holding below is affirmed.
Justice Justice Blackmun with Justices Brennan and Marshall dissenting
The state court’s determination should not have preclusive effect on Kremer’s Title VII suit in federal court. Since a state court reviews the decision of a state administrative agency for reasonableness, not de novo, the state court never reached the merits of the claim whereas the federal court now has the opportunity to do so. This decision hurts poor pro se litigants.