New York Public Personnel Law: The doctrine of res judicata held to bar litigation of employee’s challenge to termination in federal court follow dismissal of State lawsuit

September 29, 2010

The doctrine of res judicata held to bar litigation of employee’s challenge to termination in federal court follow dismissal of State lawsuit

The doctrine of res judicata held to bar litigation of employee’s challenge to termination in federal court follow dismissal of State lawsuit
Sheffield v Sheriff of the Rockland County Sheriffs Department, 08-0840-cv (2nd Cir. 9-22-2010)

Malinda Sheffield was terminated from her employment following a disciplinary proceeding in which the arbitrator found that Sheffield had filed a false workers’ compensation claim and recommended her dismissal.

Sheffield than filed a lawsuit in State Supreme Court alleging that the disciplinary action taken against her was “retaliatory.” She also alleged that the action constituted libel and violated her rights under Title VII. The court dismissed her petition in its entirety.

Prior to the Supreme Court’s issuing its decision, Sheffield filed a similar lawsuit in federal district court.

Following the dismissal of Sheffield’s petition by the federal district court, Sheffield filed an appeal with the Circuit Court of Appeals, contending that neither the doctrine of res judicata nor collateral estoppel applied with respect to her federal action.

The Circuit Court, applying New York State law, said that in New York “res judicata … bars successive litigation [of all claims] based upon the same transactions or series of connected transactions… if (1) there is a judgment on the merits … by a court of competent jurisdiction and (ii) the party against whom the doctrine is invoked was a party to the previous action….”

Considering the events underlying Sheffield’s federal action, the Circuit Court affirmed the district court’s dismissal of her complaint on the ground of res judicata and thus found it unnecessary to consider whether the doctrine of collateral estoppel would also bar her litigating her federal claims.

The Circuit Court’s decision is posted on the Internet at:
http://www.ca2.uscourts.gov/decisions/isysquery/c3b4afe8-5513-4998-88f3-9a6beb0bc6d3/13/doc/08-0840_so.pdf

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