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Harrington v. Vandalia-Butler Board of Education

United States Court of Appeals for the Sixth Circuit
649 F.2d 434 (1981)


In a prior action, Jeanne Harrington (plaintiff) brought suit against the Vandalia-Butler Board of Education (Board of Education) (defendant) in the United States District Court for the Southern District of Ohio for discrimination in former employment. Harrington sought relief under Title VII of the Civil Rights Act of 1964 (Title VII). At trial, judgment was entered in favor of Harrington and she was awarded compensatory damages. The Board of Education appealed to the United States Court of Appeals for the Sixth Circuit. The court sustained the finding of discrimination, but reversed the judgment on the grounds that Title VII does not authorize compensatory damages. While Harrington’s appeal was pending, the Supreme Court decided Monell v. Department of Social Services, 436 U.S. 658 (1978). That decision overruled Monroe v. Pape, 365 U.S. 167 (1961), and effectuated a change in the law, making municipalities subject to liability under 42 U.S.C. § 1983. As a result of this change in the law, Harrington brought this action against the Board of Education, alleging discrimination and seeking relief under § 1983. The Board of Education moved for summary judgment on the grounds that Harrington’s claim was barred by the doctrine of res judicata. The district court granted the Board of Education’s motion for summary judgment, and Harrington appealed.

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