Sunday, November 24, 2013

Kremer v. Chemical Corp. case brief

Kremer v. Chemical Corp. case brief summary
456 U.S. 461 (1982)

The Court granted certiorari to review a judgment issued by the United States Court of Appeals for the Second Circuit, which held that petitioner's claim of employment discrimination in violation of Title VII of the Civil Rights Act of 1964, 42 U.S.C.S. § 2000e et seq., was barred by the res judicata and collateral estoppel effects of a state court judgment holding that he failed to prove his claim of employment discrimination under state law.

Petitioner filed with the federal Equal Employment Opportunity Commission (EEOC) a charge of employment discrimination in violation of Title VII of the Civil Rights Act. The EEOC referred the charge to the state agency that enforced the state employment discrimination law, which investigated and found no probable cause to support petitioner's claims. Petitioner then sued in state court to set aside the adverse administrative determination, but the state court affirmed the agency decision. Subsequently, the EEOC declined to file charges, and petitioner sued in federal court. The trial and appellate courts held that the suit was barred by res judicata, and petitioner sought review.


  • The Court affirmed, holding that, because there was no affirmative showing of a clear legislative purpose in Title VII to deny res judicata or collateral estoppel effect to a state court judgment affirming that a claim of employment discrimination was unproved.
  • Because the state procedures provided for the determination of such claims offered a full and fair opportunity to litigate the merits, the federal courts were required to grant full faith and credit to the state court judgment.

The Court affirmed the judgment.

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