09-1485, 09-2218 & 09-3754 Czarniecki v. City of Chicago

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Employment
Res judicata

Where a Section 1983 claim and a Title VII claim arise from the same events, a final judgment on one claim precludes a later suit on the other.

“We reject Czarniecki’s argument that because the operative facts needed to prove a Title VII claim and a § 1983 claim are a little different, there is no claim preclusion. That approach would thoroughly undermine claim preclusion and would allow endless litigation as long as a lawyer could identify a slightly different cause of action with one element different from those in the first, second, or third lawsuits between the same parties arising from the same events. We have consistently explained: ‘Two claims are one for the purposes of res judicata if they are based on the same, or nearly the same, factual allegations.’ Brzostowski v. Laidlaw Waste Systems, Inc., 49 F.3d 337, 339 (7th Cir. 1995); accord, Prochotsky v. Baker & McKenzie, 966 F.2d 333, 334-35 (7th Cir. 1992) (affirming dismissal of second case and holding that two claims or theories of recovery (ERISA and Title VII) arising from plaintiff’s dismissal amounted to a single cause of action for purposes of claim preclusion); Smith v. City of Chicago, 820 F.2d 916, 918 (7th Cir. 1987) (although ‘one group of facts may give rise to different claims for relief upon different theories of recovery, there remains a single cause of action. . . . Once a transaction has caused injury, all claims arising from that transaction must be brought in one suit or be lost.’) (citations omitted); see also Highway J Citizens Group v. U.S. Dept. of Transportation, 456 F.3d 734, 741 (7th Cir. 2006), quoting Nevada v. United States, 463 U.S. 110, 129-30 (1983) (res judicata or claim preclusion provides that a final judgment is final ‘not only as to every matter which was offered and received to sustain or defeat the claim or demand, but as to any other admissible matter which might have been offered for that purpose’). Title VII claims are not immune from res judicata, as the plaintiff seems to suggest. See Herrmann, 999 F.2d at 225. Because both of Czarniecki’s federal claims and his new state-law claims are based on the same set of factual allegations as his § 1983 claim, res judicata bars Czarniecki’s Title VII claim and his state-law claims.”

Affirmed.

09-1485, 09-2218 & 09-3754 Czarniecki v. City of Chicago

Appeals from the United States District Court for the Northern District of Illinois, St. Eve, J., Hamilton, J.

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