Friday, December 27, 2013

Harrington v. Vandalia-Butler Board of Education case brief

Harrington v. Vandalia-Butler Board of Education case brief summary
649 F.2d 434 (1981)

CASE SYNOPSIS
The Appellant challenged the order of the United States District Court (Southern District of Ohio) which granted summary judgment to the appellees on  the appellant's action for employment discrimination under 42 U.S.C.S. §1983.

CASE FACTS
Appellant's judgment under Title VII of the Civil Rights Act of 1964 was reversed because Title VII did not authorize the award of compensatory damages.
On the appellant's subsequent claim under 42 U.S.C.S. §1983, the district court granted summary judgment to the appellee board and individuals, having found that appellant's §1983 claim was barred by res judicata.
The appellant challenged the ruling, contending that she was not given the required notice of appeal under Fed. Rule of Civil Procedure 56(c).

DISCUSSION
  • The court held that the court's grant within 8 days of the appellee individuals' motion did not afford the appellant sufficient time to respond. 
  • Appellant also argued that her §1983 claim could not be barred.  This was because it was unavailable when she first filed the suit. 
  • The court further found that since her claim had already been determined on the merits, a §1983 claim was barred because, despite the result, which was unfair, the appellant did not suffer manifest injustice.
CONCLUSION
The court reversed the grant of summary judgment to appellee individuals.
This was because the district court did not give the appellant adequate notice to respond.
The district court's holding was affirmed in that the appellant's claim was barred by res judicata.
The underlying issues of the case had already been determined on the merits.

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