VAIRRUN STRICKLAND v. CITY OF MARKHAM and ANTHONY MAZZIOTTA
June 8, 2026·24-3262·Panel Decision·By Aisha Johnson
The Seventh Circuit addressed the claim preclusion principles affecting a public employee's civil rights claims. The court affirmed in part and vacated in part the district court's summary judgment ruling.
Vairrun Strickland, a firefighter, was terminated and subsequently filed lawsuits challenging his firing under various legal theories, including Title VII and the Fourteenth Amendment.
The court’s reasoning
The court determined that the district court incorrectly applied claim preclusion principles by treating the Board’s decision and the state-court lawsuit as equivalent. It clarified that Title VII claims cannot be precluded by unreviewed state administrative proceedings, while other claims could be precluded under Illinois law.
What it means going forward
Strickland’s Title VII claims will proceed, while his other claims remain dismissed.
