Harriet Walczak v. Chicago Board of Education
2014 U.S. App. LEXIS 556
| 7th Cir. | 2014Background
- Walczak taught in Chicago Public Schools since 1970 and faced a performance-remediation program under a new Wells HS principal in 2006–2007.
- She alleged age bias, claiming the principal treated older teachers as 'dinosaurs' and targeted her in remediation.
- In 2008 Walczak was not renewed as tenured staff after remediation; she was reassigned and then discharged in June 2008.
- She filed an EEOC ADEA charge in July 2008 while state discharge proceedings continued; a hearing in 2009 recommended reinstatement, but the Board terminated her in 2010.
- Walczak sought judicial review of the Board’s decision in state court; the circuit court and Illinois Appellate Court upheld the Board’s decision.
- After a right-to-sue letter in 2011, Walczak filed a federal ADEA suit; the Board moved to dismiss on claim-preclusion grounds, which the district court granted.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether Walczak’s ADEA claim is precluded | Walczak could have joined in state court action. | Preclusion bars second suit on same claim. | Yes; ADEA claim precluded. |
| Whether there was acquiescence to claim-splitting | Board acquiesced by not objecting to split. | No acquiescence; not required to object earlier. | No acquiescence; no exception applied. |
| Whether Walczak had a full and fair opportunity to litigate | State court proceedings mirrored federal claim; consolidation possible. | State court review limited to Illinois proceedings; proper to preclude later suit. | Walczak had opportunity but preclusion still applies. |
| Whether it would be inequitable to apply preclusion | Splitting claims was necessary; inequity. | No inequity; Board did not acquiesce and rule promotes efficiency. | Not inequitable; preclusion preserved. |
Key Cases Cited
- Dookeran v. County of Cook, 719 F.3d 570 (7th Cir. 2013) (joins state-court and federal claims; supports preclusion framework)
- Garcia v. Village of Mount Prospect, 360 F.3d 630 (7th Cir. 2004) (requires joining federal civil-rights claim with state-review action)
- Blount v. Stroud, 904 N.E.2d 1 (Ill. 2009) (Illinois precedent on jurisdiction and claim-splitting)
- Rein v. David A. Noyes & Co., 665 N.E.2d 1199 (Ill. 1996) (Restatement-based equitable exception to preclusion)
- River Park, Inc. v. City of Highland Park, 703 N.E.2d 883 (Ill. 1998) (restatement guidance on transactional test and preclusion scope)
- Matrix IV, Inc. v. Am. Nat’l Bank & Trust Co., 649 F.3d 539 (7th Cir. 2011) (preclusion aims to minimize duplication and ensure finality)