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Astoria Federal Savings and Loan Association v. Solimino,
501 U.S. 104 (1991)
The Plaintiff, Solimino, felt that he was fired from his job because of his
age. The EEOC referred him, under a workshare agreement, to the New York State
Division of Human Rights. That agency dismissed his claim because it found no
probable cause to believe that the Plaintiff was fired because of his age. That
decision was upheld on administrative appeal. Solimino then filed a lawsuit in
federal court seeking relief under the ADEA and various state laws. The district
court dismissed the claim based on issue preclusion, but the Second Circuit reversed.
The Supreme Court weighed in to resolve a difference in law between the Circuits
as to the preclusive effect given to prior state administrative decisions. The
Supreme Court held that the ADEA carries an implication that federal courts should
recognize no issue preclusion by state administrative findings with respect to
age discrimination claims. This conclusion was based on the fact that the ADEA
requires parties to "file with state authorities before filing in Federal
Court" and that the ADEA "provides that no suit may be brought in Federal
Court before the expiration of 60 days after proceedings have been commenced under
state law, unless such proceedings have been earlier terminated." The Court
held that both statements clearly contemplate the possibility of federal consideration
after state agencies have finished theirs.
The Supreme Court in Astoria upheld the Second Circuit, allowing Solimino’s
discrimination claims to proceed in the federal courts.
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