Keith Dookeran v. Cook County
2013 U.S. App. LEXIS 9042
| 7th Cir. | 2013Background
- Dookeran was employed by Stroger Hospital in 2000 with biennial reappointments.
- In 2004 he disclosed a Mercy Hospital reprimand for hostile work environment, triggering hospital peer review.
- The credentials committee and peer-review process led to suspension/denial of staff privileges and reappointment.
- Dookeran pursued state-court certiorari review; while pending, he filed discrimination charges with IDHR and EEOC.
- State courts ultimately denied relief; after a delay, EEOC issued a right-to-sue letter and he sued in federal court under Title VII.
- District court dismissed on res judicata grounds; issue is whether preclusion and jurisdictional bars apply.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether Rooker-Feldman deprives federal jurisdiction | Dookeran seeks federal relief for state-court judgments | Rooker-Feldman bars review of state-court judgments in federal court | Rooker-Feldman does not apply; jurisdiction is secure |
| Whether Title VII claims are precluded by state-court action | Dookeran had full and fair opportunity to litigate federal claims | Illinois law preclusion applies, barring those claims | Yes, claim preclusion applies given full and fair opportunity to litigate |
| Whether Blount v. Stroud affects preclusion analysis | Blount unlocked circuit court jurisdiction for federal claims | Blount modifies the jurisdictional framework but preclusion remains | Preclusion applied; Blount did not alter result here |
Key Cases Cited
- Garcia v. Village of Mount Prospect, 360 F.3d 630 (7th Cir. 2004) (federal claims may be joined with administrative-review actions under Illinois law)
- Kremer v. Chemical Construction Corp., 456 U.S. 461 (1982) (due-process considerations limit claim preclusion when no full and fair opportunity to litigate)
- River Park, Inc. v. City of Highland Park, 184 Ill.2d 290 (Ill. 1998) (transactional approach to identity of claims for preclusion)
- Blount v. Stroud, 328 Ill.Dec. 239 (Ill. 2009) (state courts may hear federal civil-rights claims; Blount unlocked circuit-court jurisdiction (discussed but not controlling))
- Stratton v. Wenona Cmty. Unit Dist. No. 1, 133 Ill.2d 413 (Ill. 1990) (federal due process claims in state court context; relevant conflicts with Cahoon line)
- Stykel v. City of Freeport, 318 Ill.App.3d 839 (Ill.App. 2001) (federal civil-rights claims in state court context; discrimination not explicit)
- Cahoon v. Alton Packaging Corp., 148 Ill.App.3d 480 (Ill.App. 1986) (IHRA's jurisdictional bar; prohibits state court jurisdiction over federal claims under Cahoon line)
- Meehan v. Illinois Power Co., 347 Ill.App.3d 761 (Ill.App. 2004) (federal claims treated as state-law discrimination claims under IHRA)
- Brewer v. Bd. of Trustees of Univ. of Illinois, 339 Ill.App.3d 1074 (Ill.App. 2003) (IHRA precludes state court jurisdiction for certain discrimination claims)