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Staats v. Cty. of Sawyer - 220 F.3d 511 (7th Cir. 2000)

Rule:

The circuits are split as to whether Title II of the Americans with Disabilities Act, 42 U.S.C.S. § 12101 et seq., covers discrimination by public entities in their employment practices

Facts:

Appellant sought review from judgment of United States District Court for Western District of Wisconsin, which granted appellee's motion for summary judgment against appellant's claims, pursuant to Titles I and II of the Americans with Disabilities Act, 42 U.S.C.S. § 12101 et seq., and the Rehabilitation Act of 1973,  29 U.S.C.S. § 794 et seq., on the ground of claim preclusion. Appellant was diagnosed with a bi-polar disorder. After receiving treatment, appellant attempted to return to work, but was informed that his job had been eliminated. Appellant pursued his state administrative remedies, including a Wisconsin Fair Employment Act claim in the Equal Rights Division, but his claims were rejected. Appellant filed in the federal court, alleging violations of Title I and II of the Americans with Disabilities Act, 42 U.S.C.S. § 12101 et seq., and the Rehabilitation Act of 1973, 29 U.S.C.S. § 794 et seq. The district court granted summary judgment to appellees on the ground of claim preclusion. 

Issue:

Was appellant precluded from bringing his federal claims in another forum?

Answer:

No

Conclusion:

Appellant sought review and judgment was reversed and remanded with instructions because Wisconsin would have permitted claim splitting under the circumstances. Appellant's Wisconsin Fair Employment Act claims had to be adjudicated in the Equal Rights Division, a forum of limited jurisdiction. Consequently, appellant was not precluded from bringing his federal claims in another forum.

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