Staats v. County of Sawyer

Brief Fact Summary.

Plaintiff sued Defendants, alleging violations of Wisconsin’s state discrimination laws. The case was dismissed in state court. After receiving a “right to sue” letter from the EEOC, Plaintiff sued Defendants in federal district court. The district court granted Defendants’ motion for summary judgment and dismissed the claims.

Synopsis of Rule of Law.

A claim is not precluded if the previous action was heard in a court that did not have jurisdiction over the current claim.

Facts.

Edward Staats (Plaintiff) was the personnel director for Sawyer and Bayfield counties (Defendants) in Wisconsin. He served in this position starting in May 1993. In September 1994, Plaintiff was hospitalized for bi-polar disorder. He attempted to return to work in November 1994 under conditions set by his doctor. However, before Plaintiff could resume work, Defendants counties told him that his position had been eliminated. Plaintiff believed this to be an attempt to discriminate against him and brought charges under Wisconsin’s state discrimination laws. Following litigation before administrative bodies, Plaintiff’ case was appealed to a Wisconsin state court, where it was dismissed. Shortly after dismissal Plaintiff brought a claim before the EEOC that Defendants counties violated the Americans with Disabilities Act. After receiving a “right to sue letter” from the EEOC, Plaintiff sued Defendants counties in federal district court. Defendants counties moved for summary judgment, claiming that the federal counts were precluded from being heard in federal court due to previous discrimination claims heard in state court. The district court agreed and dismissed the claims.

Issue.

Whether a claim is precluded if the court that heard the previous suit did not have jurisdiction over the current claim.

Held.

No. The trial court’s ruling is reversed and the case is remanded for further proceedings. A claim is not precluded if the previous action was heard in a court that did not have jurisdiction over the current claim.

Discussion.

The doctrine of claim preclusion exists in order to require litigants to bring their claims in as few suits as possible. This process encourages judicial economy and allows courts to function more efficiently. One element of determining whether or not a claim is precluded is determining whether the prior suit ended with a final judgment issued by a court with jurisdiction. In this case, there was a final judgment on the state law claims. Further, the Wisconsin state court had jurisdiction over discrimination claims brought under Wisconsin state law. However, the Wisconsin state courts did not have jurisdiction over federal discrimination claims. This lack of jurisdiction means that it would have been legally impossible for Plaintiff to bring his federal claims in state court. Therefore, his federal claims are not precluded from being heard in federal court in spite of the state court action.