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.
Rule of Law
Holding and Reasoning (Martin, J.)
What to do next…
Unlock this case brief with a free (no-commitment) trial membership of Quimbee.
You’ll be in good company: Quimbee is one of the most widely used and trusted sites for law students, serving more than 97,000 law students since 2011. Some law schools—such as Yale, Vanderbilt, Berkeley, and the University of Illinois—even subscribe directly to Quimbee for all their law students. Read our student testimonials.
Learn more about Quimbee’s unique (and proven) approach to achieving great grades at law school.
Quimbee is a company hell-bent on one thing: helping you get an “A” in every course you take in law school, so you can graduate at the top of your class and get a high-paying law job. We’re not just a study aid for law students; we’re the study aid for law students. Read more about Quimbee.
Here's why 175,000 law students have relied on our case briefs:
- Written by law professors and practitioners, not other law students. 14,000 briefs, keyed to 188 casebooks. Top-notch customer support.
- The right amount of information, includes the facts, issues, rule of law, holding and reasoning, and any concurrences and dissents.
- Access in your classes, works on your mobile and tablet. Massive library of related video lessons and high quality multiple-choice questions.
- Easy to use, uniform format for every case brief. Written in plain English, not in legalese. Our briefs summarize and simplify; they don’t just repeat the court’s language.