There may be a controversy brewing in the Eastern District of Pennsylvania. The issue stems from a recent decision regarding the preclusive effect of administrative proceedings from the Unemployment Compensation Board of Review (UCBR) in a subsequent federal court discrimination lawsuit alleging similar facts. The results are two starkly different interpretations of a longstanding Pennsylvania Supreme Court precedent by members of the same court.
The case at hand is Mathis v. Christian Heating and Air Conditioning, PICS Case No. 14-1644 (E.D. Pa. Oct. 7, 2014) DuBois, J. (26 pages). Let us first start with the background. In Mathis, the plaintiff, Paul Mathis, sued his former employer under Title VII, alleging that he was denied a reasonable religious accommodation and suffered a retaliatory discharge due to his religious beliefs and request for a reasonable accommodation. The employer, Christian Heating and Air Conditioning Inc., asked the court to dismiss the claims, arguing that Mathis already received a full and fair opportunity to litigate the identical issues in his underlying unemployment claim and therefore was collaterally estopped.
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