McDonald v. Adamson

Dist. Ct. erred in granting defendants-prison officials’ motion to dismiss plaintiff-prisoner’s section 1983 claim alleging that defendants violated his First Amendment rights by failing to accommodate his Muslim religion, where basis for dismissal was Dist. Ct.’s belief that res judicata applied to preclude plaintiff from prosecuting instant action due to prior decision by Illinois Ct. of Claims that denied plaintiff’s similar lawsuit. Res judicata could not apply to preclude plaintiff from seeking relief in instant lawsuit since: (1) Illinois law affords preclusive effect only to final judgment rendered by “court of competent jurisdiction;" and (2) Illinois Ct. of Claims is not “court” within meaning of article VI of Illinois Constitution. Moreover, Ct. of Claims lacked jurisdiction to consider any claim based upon federal statute or federal or state constitutions.