Kremer v. Chemical Corp

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.

Facts.

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.

Issue.

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?

Held.

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

Dissent.

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.

Discussion.

1. Title VII does not override § 1738.
2. § 1738 states that final judgements from one state are given full faith and credit in all other states. This means federal courts must give preclusive effect to judgements arising out of state courts.
3. The court will not read in exceptions to § 1738 if Congress does not state them explicitly.
4. The court does not accept Kremer’s argument that § 1738 does not apply to Title VII actions because Title VII does not explicitly state that Congress wanted federal courts to not give finality to state court decisions on Title VII matters.
5. The statute also does not require a claimant to appeal an unfavorable state agency ruling in state court.
6. According to Kremer’s argument, a claimant would be able to file suit in federal court for de novo review after an unfavorable ruling in state court. The Court will not read this in unless Congress explicitly stated it, which it did not.
7. Federalism is not compromised by reading Title VII as not overriding § 1738 because the opposite, allowing federal courts to review de novo claims that were already brought in state court, would be much worse.
8. There are also sufficient procedural safeguards to ensure the claimant has his claim fully and fairly heard.
The holding below is affirmed.