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Kremer v. Chemical Constr. Corp., 456 U.S. 461 (1982)
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General SummaryThis case is from a collection containing the full text of over 16,000 Supreme Court cases from 1793 to the present. The body of Supreme Court decisions are, effectively, the final interpretation of the Constitution. Only an amendment to the Constitution can permanently overturn an interpretation and this has happened only four times in American history.
Kremer v. Chemical Constr. Corp., 456 U.S. 461 (1982)
Kremer v. Chemical Construction Corp. No. 80-6045 Argued December 7, 1981 Decided May 17, 1982 456 U.S. 461
CERTIORARI TO THE UNITED STATES COURT OF APPEALS FOR
THE SECOND CIRCUIT
Syllabus
Title 28 U.S.C. § 1738 (as did its predecessors dating back to 1790) requires federal courts to afford the same full faith and credit to state court judgments that would apply in the State’s own courts. Petitioner filed an employment discrimination charge with the Equal Employment Opportunity Commission (EEOC) under Title VII of the Civil Rights Act of 1964, and the EEOC, as required by the Act, referred the charge to the New York State Division of Human Rights (NYHRD), the agency charged with enforcing the New York law prohibiting employment discrimination. The NYHRD rejected the claim as meritless, and was upheld on administrative appeal. The Appellate Division of the New York Supreme Court affirmed. Subsequently, a District Director of the EEOC ruled that there was no reasonable cause to believe that the discrimination charge was true, and issued a right-to-sue letter. Petitioner then brought a Title VII action in Federal District Court. Ultimately, the District Court dismissed the complaint on res judicata grounds, and the Court of Appeals affirmed.
Held: The District Court was required under 28 U.S.C. § 1738 to give preclusive effect to the state court decision upholding the state administrative agency’s rejection of the employment discrimination claim. Pp. 466-485.
(a) Where, under New York law, the New York court’s determination precludes petitioner from bringing any other action based on the same grievance in the New York courts, § 1738, by its terms, precludes him from relitigating the same question in federal courts. Pp. 466-467.
(b) There is no "affirmative showing" of a "clear and manifest" legislative purpose in Title VII to deny res judicata or collateral estoppel effect to a state court judgment affirming that an employment discrimination claim is unproved. An exception to § 1738 will not be recognized unless a later statute contains an express or implied partial repeal. Allen v. McCurry, 449 U.S. 90. Here, there is no claim that Title VII expressly repealed § 1738, and no implied repeal is evident from the language, operation, or legislative history of Title VII, there being no manifest incompatibility between Title VII and § 1738. Pp. 468-476.
(c) While initial resort to state administrative remedies does not deprive an individual of a right to a federal trial de novo on a Title VII claim, this does not mean that a prior state court judgment can be disregarded. Alexander v. Gardner-Denver Co., 415 U.S. 36, distinguished. The comity and federalism interests embodied in § 1738 are not compromised by the application of res judicata and collateral estoppel in Title VII cases. Rather, to deprive state judgments of finality not only would violate basic tenets of comity and federalism, but also would reduce the incentive for States to work toward effective and meaningful systems prohibiting employment discrimination. Pp. 476-478.
(d) The procedures provided in New York for the determination of employment discrimination claims, complemented by administrative as well as judicial review, offer a full and fair opportunity to litigate the merits, and thus are sufficient under the Due Process Clause of the Fourteenth Amendment. State proceedings need do no more than satisfy the minimum procedural requirements of the Due Process Clause in order to qualify for the full faith and credit guaranteed by federal law. Section 1738 does not allow federal courts to employ their own rules of res judicata in determining the effect of state judgments, but rather goes beyond the common law and commands a federal court to accept the rules chosen by the State from which the judgment is taken. Here, petitioner received all the process that was constitutionally required in rejecting his employment discrimination claim. Pp. 479-485.
623 F.2d 786, affirmed.
WHITE, J., delivered the opinion of the Court, in which BURGER, C.J., and POWELL, REHNQUIST, and O’CONNOR, JJ., joined. BLACKMUN, J., filed a dissenting opinion, in which BRENNAN and MARSHALL, JJ., joined, post, p. 486. STEVENS, J., filed a dissenting opinion, post, p. 508.
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Chicago: U.S. Supreme Court, "Syllabus," Kremer v. Chemical Constr. Corp., 456 U.S. 461 (1982) in 456 U.S. 461 456 U.S. 462. Original Sources, accessed November 24, 2024, http://originalsources.com/Document.aspx?DocID=VPL6HJP8J78699E.
MLA: U.S. Supreme Court. "Syllabus." Kremer v. Chemical Constr. Corp., 456 U.S. 461 (1982), in 456 U.S. 461, page 456 U.S. 462. Original Sources. 24 Nov. 2024. http://originalsources.com/Document.aspx?DocID=VPL6HJP8J78699E.
Harvard: U.S. Supreme Court, 'Syllabus' in Kremer v. Chemical Constr. Corp., 456 U.S. 461 (1982). cited in 1982, 456 U.S. 461, pp.456 U.S. 462. Original Sources, retrieved 24 November 2024, from http://originalsources.com/Document.aspx?DocID=VPL6HJP8J78699E.
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