Huon v. Johnson & Bell, Ltd.

Dist. Ct. erred in issuing on abstention grounds stay of instant Title VII action alleging that defendant terminated plaintiff on account of his race and national origin, where stay was based on Dist. Ct.'s belief that plaintiff's claims would eventually be barred by res judicata once adverse judgment in plaintiff's state case against defendants (alleging defamation and intentional infliction of emotional distress arising out of defendants' issuance of negative evaluation) had become final. Dist. Ct.'s anticipation of outcome in state case was not enough to justify abstention given Supreme Ct. admonition not to stay federal action without articulating strong justification for doing so. Moreover, while instant federal action may eventually be barred by res judicata, defendants should not be allowed to stall federal action in order to wait for favorable state court action to become final.