Schandelmeier-Bartels v. The Chicao Park District

Illinois Appellate Court
Civil Court
Collateral Estoppel
Citation
Case Number: 
2015 IL App (1st) 133356
Decision Date: 
Friday, January 23, 2015
District: 
1st Dist.
Division/County: 
Cook Co., 5th Div.
Holding: 
Affirmed.
Justice: 
GORDON
Plaintiff, who is Caucasian, was terminated from her employment with Chicago Park District after she reported alleged child abuse of African-American child by his aunt to DCFS, and filed retaliatory discharge claim in state court. Plaintiff had previously filed federal employment racial discrimination suit, and federal jury had awarded her $200,000 compensatory damages. Plaintiff's right to refile her claim in state court did not immunize her from application of doctrine of collateral estoppel. Thus, because federal jury already decided her damages, which were identical to those sought in her state law case. Plaintiff is prevented from pursuing her state-law claim by doctrine of collateral estoppel. (McBRIDE and REYES, concurring.)