## Facts

- Angelo Solimino worked for Astoria Federal Savings and Loan Association for nearly 40 years and was terminated at age 63 from a vice president position.
- Within two weeks of termination, Solimino filed an age-discrimination charge under the Age Discrimination in Employment Act (ADEA) with the EEOC.
- Under a worksharing arrangement, the EEOC referred the charge to the New York State Division of Human Rights (NYSDHR).
- After a hearing with counsel for both parties, NYSDHR found no probable cause to believe age discrimination occurred; the State Human Rights Appeal Board affirmed on administrative review.
- Solimino did not seek judicial review of the state administrative determination in state court.
- Solimino then filed an ADEA action in federal district court based on the same underlying events.
- The district court granted summary judgment for Astoria on collateral-estoppel grounds; the Second Circuit reversed.

## Issues

1. Whether judicially unreviewed findings of a state administrative agency rejecting an age-discrimination claim have collateral-estoppel effect in a subsequent federal ADEA action arising from the same facts.

## Decision

- The Supreme Court unanimously affirmed the Second Circuit.
- Judicially unreviewed state administrative findings have no preclusive effect on a federal ADEA action.
- Although there is a general presumption that administrative factfinding may have preclusive effect, that presumption yields when it conflicts with the statute’s design.
- The ADEA’s deferral and filing scheme contemplates federal judicial consideration after completion of state administrative proceedings; giving preclusive effect would make the anticipated federal forum largely meaningless.

## Legal Principles

- Common-law preclusion principles may be presumed to apply to administrative determinations, but only when consistent with congressional intent reflected in the relevant statutory scheme.
- Congress need not use an express “no preclusion” clause to displace administrative estoppel; inconsistency with the statute’s structure and purposes is sufficient.
- The ADEA’s requirement that claimants commence state proceedings in deferral states, coupled with authorization to sue federally after state proceedings end, indicates that unreviewed state administrative determinations cannot bar the federal ADEA claim.
- The holding is limited to judicially unreviewed state administrative findings and does not address the effect of state-court judgments.

## Conclusion

The Court held that unreviewed state administrative determinations rejecting age-discrimination claims do not collaterally estop later federal litigation under the ADEA because preclusion would conflict with the ADEA’s procedural scheme that anticipates access to a federal forum after state proceedings conclude.


Astoria Fed. Sav. & Loan Ass’n v. Solimino, 501 U.S. 104 (1991)