By: Derek Hawkins//October 24, 2016//
7th Circuit Court of Appeals
Case Name: Donald Lee McDonald v. George Adamson
Case No.: 15-1305
Officials: BAUER, POSNER, and MANION, Circuit Judges
Focus: 1st Amendment – Freedom of Religion
In 2013, Illinois state prison inmate Donald McDonald filed what should have been a typical federal constitutional suit under 42 U.S.C. § 1983. McDonald alleged that Defendants Warden Marcus Hardy, Assistant Warden Daryl Edwards, and Chaplain George Adamson were denying his First Amendment free exercise rights as a practicing Muslim. He sought only injunctive relief in the district court. McDonald’s case hit a procedural snag because three years earlier he had filed a claim for damages based on the same facts in the Illinois Court of Claims. More than two years later, when he had received no decision from the Court of Claims, he filed this case pro se in the district court. After the Court of Claims denied McDonald’s request for relief, the district court dismissed his federal complaint as barred by res judicata. On appeal, defendants concede that McDonald’s suit is not barred by res judicata. Therefore, we reverse the judgment of the district court and remand for proceedings in conformity with this opinion. We express no opinion regarding the merits of defendants’ remaining arguments on appeal, which are not properly before the court at this stage.
Reversed and Remanded