Czarniecki v. City of Chicago
2011 U.S. App. LEXIS 1177
| 7th Cir. | 2011Background
- Czarniecki, a probationary Chicago police officer, was dismissed in February 2007.
- In September 2007 Czarniecki sued City of Chicago and Tobias under § 1983 alleging national-origin discrimination in violation of the Fourteenth Amendment.
- District court granted summary judgment for the City on the § 1983 claim; Czarniecki dismissed his claim against Tobias without prejudice under Rule 41(a)(2).
- In May 2009 Czarniecki filed a second action alleging Title VII discrimination based on national origin, with supplemental state-law claims.
- District court dismissed the Title VII and state-law claims as barred by claim preclusion arising from the prior § 1983 suit.
- Czarniecki appeals the res judicata ruling; the City asks that the other related appeals be dismissed as moot.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether Title VII claims are precluded by res judicata | Czarniecki argues separate Title VII rights may be pursued after § 1983 adjudication. | City contends final § 1983 judgment bars Title VII under claim preclusion. | Yes; Title VII and related state claims are barred. |
| Whether the § 1983 final judgment was effectively final despite Rule 41(a) dismissal | Czarniecki contends dismissal without prejudice defeats finality for res judicata. | City contends the district court's prior summary judgment created a final judgment for purposes of res judicata. | Yes; final judgment existed for res judicata purposes. |
| Whether the same parties and same operative facts support claim preclusion | Czarniecki asserts differing theories undermine same-transaction analysis. | City asserts same parties and same core facts support preclusion. | Yes; same parties and same operative facts established claim preclusion. |
| Whether Czarniecki could have stayed the first case to obtain a Title VII right-to-sue letter | Czarniecki argues a stay would have avoided preclusion. | City argues no stay is required; options existed to pursue remedies concurrently or delay. | No; stay was not required and failure to stay does not defeat preclusion. |
| Whether the related appeals are moot | Czarniecki contends ongoing issues should be decided. | City argues no live controversy remains after dismissal on res judicata grounds. | Moot; related appeals dismissed. |
Key Cases Cited
- Mostly Memories, Inc. v. For Your Ease Only, Inc., 526 F.3d 1093 (7th Cir. 2008) (finality for dismissal without prejudice depends on case completion)
- Hill v. Potter, 352 F.3d 1142 (7th Cir. 2003) (finality standard for case termination and res judicata)
- Parvati Corp. v. City of Oak Forest, 630 F.3d 512 (7th Cir. 2010) (abrogates improper distinctions in res judicata analysis)
- Brzostowski v. Laidlaw Waste Systems, Inc., 49 F.3d 337 (7th Cir. 1995) (same transaction test for res judicata)
- Prochotsky v. Baker & McKenzie, 966 F.2d 333 (7th Cir. 1992) (two claims from same event constitute single cause of action)
- Smith v. City of Chicago, 820 F.2d 916 (7th Cir. 1987) (single cause of action; different theories still within same transaction)
- Nevada v. United States, 463 U.S. 110 (1983) (final judgment extends to matters admissible for purposes of claim)
- Herrmann v. Cencom Cable Associates, Inc., 999 F.2d 223 (7th Cir. 1993) (Title VII claims not immune from preclusion in appropriate context)
- United States ex rel. Lusby v. Rolls-Royce Corp., 570 F.3d 849 (7th Cir. 2009) (application of res judicata in federal context)
- In re Ingersoll, Inc., 562 F.3d 856 (7th Cir. 2009) (restatement of res judicata principles for federal judgments)