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Migra v. Warren City School District Board of Education

465 U.S. 75 (1984)

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Migra v. Warren City School District Board of Education

United States Supreme Court

465 U.S. 75 (1984)

Facts

Dr. Ethel Migra (plaintiff) was employed by the Warren City School District Board of Education (the Board) (defendant) as the supervisor of elementary education. The Board voted not to renew Dr. Migra’s contract. Dr. Migra sued the Board in Ohio state court for breach of contract, and the trial court ruled in Dr. Migra’s favor. The state court of appeals affirmed. Although Dr. Migra could have originally sued the Board in federal court under 42 U.S.C. § 1983 for deprivation of her right to due process, Dr. Migra chose to bring this claim in federal court after the state court case had concluded. The district court granted the Board’s motion for summary judgment based on res judicata, but it did not specify whether this dismissal was based on Ohio or federal law. The court of appeals affirmed. The United States Supreme Court granted certiorari.

Rule of Law

Issue

Holding and Reasoning (Blackmun, J.)

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