Council v. Dolton

Federal 7th Circuit Court
Civil Court
Collateral Estoppel
Citation
Case Number: 
No. 13-2654
Decision Date: 
August 22, 2014
Federal District: 
N.D. Ill., E. Div.
Holding: 
Reversed and remanded
Dist. Ct. erred in dismissing on collateral estoppel grounds plaintiff’s section 1983 action alleging that he was terminated in violation of his due process and freedom of speech rights, where said dismissal was based on prior Appellate Court finding that plaintiff was not eligible for Illinois unemployment insurance benefits because plaintiff had constructively resigned his position by failing to obtain required commercial driver’s license. Section 1900B of Unemployment Insurance Act precluded Dist. Ct. from applying collateral estoppel based on Appellate Court ruling since results of plaintiff’s unemployment insurance claim could not be used as evidence in any other judicial proceeding.