Staats v. County Of Sawyer

220 F.3d 511 (7th Cir. 2000)

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Nature of the Case

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Facts

P began working as the full-time personnel director for Ds in May 1993 under an arrangement whereby he split his time between them. In September 1994, P began acting strangely. P learned that he suffers from bipolar disorder. He was hospitalized in September and again in October and remained in the hospital until mid-November. In late November 1994, he attempted to return to work. Ds told him that he needed a release from his doctor. He complied, but the work release his doctor gave him restricted him to 'working no more than 40 hours per week, taking no work home to complete after hours, attending regular therapy sessions with psychiatrists, in compliance with his medication, monthly laboratory testing of medication blood level and abstinence from alcohol for the next 90 days.' On December 19, Ds' attorney informed P that he could continue to work until the end of the calendar year, at which time his job position itself would be eliminated. P filed a claim of employment discrimination with the State of Wisconsin Equal Rights Division. The Equal Rights Division found probable cause to believe that Ds had discriminated against P and certified the matter to a hearing before an administrative law judge. The ALJ issued a decision concluding that Ds had violated the WFEA and had failed to determine what sort of accommodation P might need. On appeal, that decision was reversed. P sought review under the Wisconsin state administrative review procedures. The state court conducted a review limited to the administrative record, as it was required to do by statute. It upheld the decision. Two weeks after P filed his Equal Rights Division complaint, he cross-filed with the EEOC. P received his right-to-sue letter and filed the present action in federal district court. Ds filed a motion for summary judgment on the basis that the state court decision barred the federal court action under the doctrine of claim preclusion. The district court agreed and entered judgment for Ds. P appealed.