White v. City of Pasadena

State court decisions and reviewed administrative decisions in federal discrimination claims are entitled to the same preclusive effect that any other decision would be given in the courts of that state.

City of Pasadena Police Officer Karen White filed three lawsuits against the city over a period of three years. The first (“White I”) alleged the city fired her because she had associated with a known drug dealer. She claimed discrimination because she has a disability (multiple sclerosis) and was reinstated on statute of limitations grounds but, on appeal, the lawsuit was decided in favor of the city. Before White I went to trial, White was again fired after an alleged suicide attempt about which the city determined she had made false statements to law enforcement. She pursued an administrative appeal of her second firing (“White II”), with the arbiter finding in her favor, but the city manager terminated her anyway. The California Court of Appeal found in favor of the city, and White did not seek further review. While White I was on appeal and the proceedings in White II were still pending, White filed another lawsuit against the city (“White III”), alleging a pattern of discrimination and harassment by the city because of her disability. The issue before the Court was whether White’s claims and issues in White III were precluded by the judicial actions in White I and White II. The Court found that under 28 U.S.C. § 1738, it was obligated to apply California’s principles of issue and claim preclusion, and in doing so, if found that White I precluded White from arguing that the city had harassed or discriminated against her based on perceived disabilities and White II precluded her from arguing that her termination was a pretext for retaliation. Because these issues were precluded, there were no valid claims left in White III, so the court upheld its dismissal. AFFIRMED.