Preclusive Effect of Administrative Findings

Caton v. City of Pelham, [Ms. 1190589, Dec. 11, 2020], ___ So. 3d ___ (Ala. 2020). The Court (Mendheim, J.; Parker, C.J., and Bolin, Shaw, Wise, Bryan, Sellers, and Stewart, JJ., concur; Mitchell, J., concurs specially) affirms the Shelby Circuit Court’s summary judgment dismissing Caton’s retaliatory discharge claim against the City of Pelham. A prior administrative proceeding resulted in a finding that Caton had been terminated for misconduct and consequently was not entitled to unemployment benefits. Ms. **17-18. The circuit court held that “Caton was collaterally estopped from asserting a retaliatory-discharge claim against the City because Caton had been denied unemployment compensation on the basis of a determination that his employment had been terminated for misconduct.” Ms. *36. The Court affirms and rejects Caton’s argument that applying collateral estoppel based on findings in a final ruling by an administrative agency violates the right to trial by jury

Decision-making by an adjudicative tribunal is necessary for the doctrine of collateral estoppel to apply because the goal of the doctrine is “to encourage judicial economy by allowing issues ... to be decided in a single proceeding, so that there can be a final resolution of the conflict between the parties.” Ex parte Smith, 683 So. 2d 431, 436 (Ala. 1996). If Caton’s reasoning was followed, then it would also be true that any matters decided in bench trials could not have preclusive effect in subsequent cases in which jury trials are available. As the United States Supreme Court explained in Parklane Hosiery Co. v. Shore, 439 U.S. 322 (1979), however, finding preclusion based on bench-trial determinations has never been viewed as contrary to the right to trial by jury.

Ms. *47.

The Court holds “the unemployment-compensation proceedings provided the essential elements of an adjudication such that Caton had an opportunity to adequately litigate the issue whether his termination from employment with the City was based on misconduct. Therefore, applying the doctrine of collateral estoppel in this case on the basis of the determination in the administrative proceedings did not violate Caton’s right to a trial by jury.” Ms. *50.

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