Dookeran v. The County of Cook

Illinois Appellate Court
Civil Court
Res Judicata
Citation
Case Number: 
2013 IL App (1st) 111095
Decision Date: 
Friday, March 22, 2013
District: 
1st Dist.
Division/County: 
Cook Co., 6th Div.
Holding: 
Affirmed.
Justice: 
HALL
Res judicata barred Plaintiff physician's claims for retaliatory discharge and breach of contract, as appellate court had previously ruled on administrative review proceedings on identical cause of action (physician's denial of reappointment to hospital staff). Limitations on administrative review do not preclude application of doctrine of res judicata. Denial of leave to appeal by supreme court terminated litigation between parties in prior matter, and thus there was a final judgment on merits by a court of competent jurisdiction. Administrative proceedings afforded Plaintiff a full and fair opportunity to litigate the charges against him, and fundamental fairness did not bar application of res judicata. (GORDON and REYES, concurring.)