Reed v. State of Illinois

Dist. Ct. erred in dismissing on collateral estoppel grounds plaintiff’s ADA action alleging that defendants-state court officials failed to accommodate plaintiff’s tardive dyskinesia, which, according to plaintiff, prevented her from effectively proceeding in her state-court lawsuit against third-party due to its effect on her ability to communicate within courtroom. Record showed that plaintiff raised her ADA claim in post-trial motion in her state-court action, and that state court had denied plaintiff’s request for such relief, and that appellate court had affirmed jury’s verdict. Moreover, while Ct. of Appeals found that all elements of collateral estoppel had been technically satisfied, Dist. Ct. should not have applied it because: (1) state trial court had unfairly denied certain requested accommodations; and (2) plaintiff’s disability prevented her from participating in oral argument on her post-trial motion, which, in turn, prevented her from having full and fair opportunity to litigate her accommodation issue in state-court proceeding. (Dissent filed.)