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Civil Procedure Keyed to Hazard
Staats v. County of Sawyer
Facts
Edward Staats (Plaintiff) was the personnel director for Sawyer and Bayfield counties (Defendants) in Wisconsin. He served in this position starting in May 1993. In September 1994, Plaintiff was hospitalized for bi-polar disorder. He attempted to return to work in November 1994 under conditions set by his doctor. However, before Plaintiff could resume work, Defendants counties told him that his position had been eliminated. Plaintiff believed this to be an attempt to discriminate against him and brought charges under Wisconsin’s state discrimination laws. Following litigation before administrative bodies, Plaintiff’ case was appealed to a Wisconsin state court, where it was dismissed. Shortly after dismissal Plaintiff brought a claim before the EEOC that Defendants counties violated the Americans with Disabilities Act. After receiving a “right to sue letter” from the EEOC, Plaintiff sued Defendants counties in federal district court. Defendants counties moved for summary judgment, claiming that the federal counts were precluded from being heard in federal court due to previous discrimination claims heard in state court. The district court agreed and dismissed the claims.
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