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Staats v. County of Sawyer

United States Court of Appeals for the Seventh Circuit
220 F.3d 511 (2000)


Facts

Edward Staats (plaintiff) was the personnel director for Sawyer and Bayfield counties (defendants) in Wisconsin. He served in this position starting in May 1993. In September 1994, Staats was hospitalized for bi-polar disorder. He attempted to return to work in November 1994 under conditions set by his doctor. However, before Staats could resume work, Sawyer and Bayfield counties told him that his position had been eliminated. Staats believed this to be an attempt to discriminate against him and brought charges under Wisconsin’s state discrimination laws. Following litigation before administrative bodies, Staats’ case was appealed to a Wisconsin state court, where it was dismissed. Shortly after dismissal Staats brought a claim before the EEOC that Sawyer and Bayfield counties violated the Americans with Disabilities Act. After receiving a “right to sue letter” from the EEOC, Staats sued Sawyer and Bayfield counties in federal district court. Sawyer and Bayfield counties moved for summary judgment, claiming that the federal counts were precluded from being heard in federal court due to previous discrimination claims heard in state court. The district court agreed and dismissed the claims.

Rule of Law

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Issue

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Holding and Reasoning (D. Wood, J.)

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  • A “yes” or “no” answer to the question framed in the issue section;
  • A summary of the majority or plurality opinion, using the CREAC method; and
  • The procedural disposition (e.g. reversed and remanded, affirmed, etc.).

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