Monday, March 16, 2015

Collateral Estoppel and Unemployment Compensation Hearings

In the law, we have this concept called "collateral estoppel." The gist of it is that after a party litigates and loses on an issue once, the party may not litigate that issue again (sometimes called "issue preclusion"). It sounds simple, but it can get surprisingly complicated.

In Mathis v. Christian Heating and Air Conditioning, Inc. (E.D. Pa.), an employee raised some employment discrimination claims. The employer filed a motion to dismiss, arguing:
Defendant argued that plaintiff was barred under the doctrine of collateral estoppel from relitigating a range of issues that were decided against plaintiff in his state unemployment compensation proceedings that are central to his employment discrimination claims. In particular, defendant contended that plaintiff could not re-litigate whether he chose to leave his employment with defendant or was involuntarily terminated or whether he had a sincerely held religious belief that defendant had burdened, among other issues.
Well, did it work? No. It turns out that Pennsylvania's Unemployment Compensation law specifically addresses this issue:
[T]he law provides that “[n]o finding of fact or law, judgment, conclusion, or final order made with respect to a claim for unemployment compensation under [the Pennsylvania Unemployment Compensation Law] may be deemed to be conclusive or binding in any separate or subsequent action or proceeding in another forum.” 43 P.S. § 829 . . . . In short, under Pennsylvania law findings of fact and conclusions of law made with respect to claims for unemployment compensation do not have preclusive effect in subsequent actions, such as the one presently before this Court.
I learn something new every day.