Employment Discrimination Claims Properly Dismissed on the Ground of Collateral Estoppel

From Williams v New York City Transit Authority, No. 2017-02335, 505636/16, 2019 N.Y. Slip Op. 02747, 2019 WL 1549176 (N.Y.A.D. 2 Dept., Apr. 10, 2019):

We agree with the Supreme Court’s determination that, based on the prior federal determination, the plaintiff is collaterally estopped from asserting the NYSHRL causes of action. The doctrine of collateral estoppel “precludes a party from relitigating in a subsequent action or proceeding an issue clearly raised in a prior action or proceeding and decided against that party or those in privity, whether or not the tribunals or causes of action are the same” (Ryan v. New York Tel. Co., 62 N.Y.2d 494, 500, 478 N.Y.S.2d 823, 467 N.E.2d 487). The doctrine of collateral estoppel applies when: “ ‘(1) the issues in both proceedings are identical, (2) the issue in the prior proceeding was actually litigated and decided, (3) there was a full and fair opportunity to litigate in the prior proceeding, and (4) the issue previously litigated was necessary to support a valid and final judgment on the merits’ ” (Conason v. Megan Holding, LLC, 25 N.Y.3d 1, 17, 6 N.Y.S.3d 206, 29 N.E.3d 215, quoting Alamo v. McDaniel, 44 A.D.3d 149, 153, 841 N.Y.S.2d 477). “Where a federal court declines to exercise jurisdiction over a plaintiff’s state law claims, collateral estoppel may still bar those claims provided that the federal court decided issues identical to those raised by the plaintiff’s state claims” (Milione v. City Univ. of N.Y., 153 A.D.3d 807, 808–809, 59 N.Y.S.3d 796; see Karimian v. Time Equities, Inc., 164 A.D.3d 486, 488, 83 N.Y.S.3d 227; Clifford v. County of Rockland, 140 A.D.3d 1108, 1110, 35 N.Y.S.3d 211).

Here, the factual determinations made by the District Court with respect to the causes of action alleging discrimination in violation of title VII and the ADEA were determinative of the cause of action asserted in this action pursuant to the NYSHRL (see Milione v. City Univ. of N.Y., 153 A.D.3d at 809, 59 N.Y.S.3d 796; Peterkin v. Episcopal Social Servs. of N.Y. Inc., 24 A.D.3d 306, 307–308, 808 N.Y.S.2d 31; see also Singh v. Covenant Aviation Sec., LLC, 131 A.D.3d 1158, 1159–1160, 16 N.Y.S.3d 611). Further, the plaintiff was afforded a full and fair opportunity to litigate those issues in the federal action. Accordingly, we agree with the Supreme Court’s determination directing dismissal of the NYSHRL causes of action.