U.S. Supreme Court
University of Tennessee v. Elliott, 478 U.S. 788 (1986)
University of Tennessee v. Elliott
Argued April 21, 1986
Decided July 7, 1986
478 U.S. 788
When petitioner University of Tennessee informed respondent, a black employee, that he would be discharged for inadequate work performance and misconduct on the job, he requested an administrative hearing. Prior to the commencement of the administrative proceedings, respondent filed suit in Federal District Court against the University and others (also petitioners), alleging that his proposed discharge was racially motivated and seeking relief under Title VII of the Civil Rights Act of 1964 and the Reconstruction civil rights statutes. The court allowed the administrative proceedings to go forward, resulting in a ruling by an Administrative Law Judge (ALJ) (affirmed by a University Vice President on appeal) that respondent's proposed discharge was not racially motivated. Instead of seeking state court review of the administrative proceedings, respondent returned to the District Court, which granted summary judgment for petitioners on the ground that the ALJ's ruling was entitled to preclusive effect. The Court of Appeals reversed, holding that respondent's Title VII claim was governed by Kremer v. Chemical Construction Corp., 456 U. S. 461, which held that final state court judgments are entitled to full faith and credit in Title VII actions, but indicated that unreviewed determinations by state agencies do not preclude trial de novo in federal court on Title VII claims. As regards respondent's claims under the other civil rights statutes, the court held that 28 U.S.C. § 1738, which accords a state court judgment the same full faith and credit in federal courts as it would have in the State's courts, does not require that federal courts be bound by the unreviewed findings of state administrative agencies. The court also declined to fashion a federal common law of preclusion.
1. Title 28 U.S.C. § 1738 is not applicable to the unreviewed state administrative factfinding at issue here. However, federal common law rules of preclusion have been frequently fashioned in the absence of a governing statute. Because § 1738 antedates the development of administrative agencies, it does not represent a congressional determination that state administrative agency decisions should not be given preclusive effect. Pp. 478 U. S. 794-795. chanroblesvirtualawlibrary
2. The Court of Appeals correctly held that Congress did not intend unreviewed state administrative proceedings to have preclusive effect on Title VII claims, and thus a federal common law rule of preclusion would not be appropriate. The analysis in Kremer, supra, and Chandler v. Roudebush, 425 U. S. 840, of the language and legislative history of Title VII supports this conclusion. Pp. 478 U. S. 795-796.
3. However, when a state agency acting in a judicial capacity resolves disputed issues of fact properly before it which the parties have had an adequate opportunity to litigate, federal courts in actions under the Reconstruction civil rights statutes must give the agency's factfinding the same preclusive effect to which it would be entitled in the State's courts (a matter for resolution on remand here). In enacting those statutes, Congress did not intend to create an exception to general rules of preclusion, or to foreclose the adaptation of those rules to such subsequent developments as the use of administrative adjudication. Giving preclusive effect in federal courts to the factfindings of state administrative bodies acting in a judicial capacity serves both the value of enforcing repose, which underlies general principles of collateral estoppel, and the value of federalism. Pp. 478 U. S. 796-799.
766 F.2d 982, affirmed in part, reversed in part, and remanded.
WHITE, J., delivered the opinion of the Court, in which BURGER, C.J.,and POWELL, REHNQUIST, and O'CONNOR, JJ., joined, and in Parts I, II, and III of which BRENNAN, BLACKMUN, and STEVENS, JJ., joined. STEVENS, J., filed an opinion concurring in part and dissenting in part, in which BRENNAN and BLACKMUN, JJ., joined, post, p. 478 U. S. 799. MARSHALL, J., took no part in the consideration or decision of the case. chanroblesvirtualawlibrary