## Facts

- Rhoda Tang worked for the State of Rhode Island Department of Elderly Affairs (DEA).
- In 1987, Tang filed an employment-discrimination charge against DEA; the matter was resolved by settlement.
- In 1989, DEA terminated Tang’s employment.
- After her termination, Tang filed a grievance through her union under a collective-bargaining agreement, alleging unjust termination and discrimination.
- In 1991, DEA and Tang’s union allegedly agreed to submit the dispute to binding arbitration.
- The arbitration resulted in an award requiring DEA to reinstate Tang and compensate her for lost wages.
- The Rhode Island Superior Court confirmed the arbitration award.
- Tang later filed suit in federal district court based on the 1989 termination, asserting Title VII employment-discrimination claims and federal civil-rights claims, and seeking remedies including injunctive relief, attorney’s fees, and punitive damages.
- DEA moved to dismiss, arguing that res judicata (claim preclusion) barred the federal action because the arbitration award had been confirmed by a state-court judgment.

## Issues

1. Whether Tang’s federal Title VII and related civil-rights claims arising from her 1989 termination were barred by res judicata due to the prior labor-arbitration award and the Rhode Island Superior Court’s confirmation of that award.

## Decision

- The court denied DEA’s motion to dismiss.
- The court held that the prior labor arbitration did not preclude Tang from pursuing independent federal statutory claims under Title VII and related civil-rights theories.
- The court concluded that the state-court confirmation of the arbitration award did not amount to a merits adjudication of Tang’s federal statutory discrimination claims sufficient to bar the later federal suit.

## Legal Principles

- Rights enforced through a collective-bargaining agreement via labor arbitration are distinct from an employee’s federal statutory rights under Title VII and federal civil-rights statutes.
- A union’s pursuit of arbitration under a collective-bargaining agreement, even when the grievance includes discrimination allegations, does not automatically bar a later federal Title VII action seeking statutory remedies.
- A state court’s confirmation of an arbitration award generally concerns the validity and enforceability of the award, not a full adjudication of separate federal statutory claims that were not actually litigated as such in the prior proceeding.
- For claim preclusion to apply, the earlier proceeding must amount to a final judgment on the same claim; contract-based discharge disputes resolved in labor arbitration are not necessarily the same “claim” as later federal discrimination causes of action, even if they arise from the same termination.

## Conclusion

In Tang v. State of Rhode Island Department of Elderly Affairs, the District of Rhode Island held that Tang’s earlier success in union arbitration—followed by state-court confirmation of the arbitration award—did not bar her subsequent federal lawsuit alleging Title VII employment discrimination and related civil-rights violations arising out of her 1989 termination, so the case could proceed in federal court.


Tang v. State of Rhode Island Department of Elderly Affairs, 904 F. Supp. 69 (1995)