Alan Rodemaker v. City of Valdosta Board of Education, et al.
SocialSecurity DueProcess EmploymentDiscrimina
Does the Panel's ruling improperly apply res judicata to bar a Title VII claim against a school board when the claim had not yet accrued at the time of the initial § 1983 lawsuit?
The Panel required petitioner to include within his § 1983 complaint for racial discrimination against School Board members individually his separate Title VII claim against the Board itself for workplace discrimination —a claim which had not yet accrued — or forfeit this inchoate claim to the bar of res judicata . The question presented is: Does this ruling square with settled law that res judicata cannot bar claims against a new defendant emerging after petitioner filed his initial lawsuit and does it undermine Congress ’ intent that Title VII be available as an independent, parallel remedy with § 1983 so that victims of workplace discrimination have full redress for their injuries?