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Civil Procedure Keyed to Field
Harrington v. Vandalia-Butler Board of Education
Citation:
649 F.2d 434Facts
Harrington (plaintiff) filed suit against the Board of Education (defendants) in federal district court, which decided the case for Harrington and awarded her compensatory damages. On appeal, the U.S. Court of Appeals for the Sixth Circuit sustained the factual finding of discrimination, but reversed the judgment on the grounds that Title VII of the Civil Rights Act does not authorize compensatory damages. While Harrington’s appeal was pending, the U.S. Supreme Court decided Monell v. Department of Social Services, which held that municipalities (which would include the Board of Education) are “persons” subject to liability under 42 U.S.C. § 1983. This decision would make Harrington eligible for damages under the factual finding of discrimination. Harrington then brought another action in the district court, alleging discrimination and seeking relief under § 1983. The district court granted the defendants’ motion for summary judgment, on the ground that Harrington’s claim was barred by res judicata. Harrington appealed.
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