## Facts

- The University of Tennessee notified Robert B. Elliott, a Black employee, that it intended to discharge him for inadequate performance and misconduct.
- Elliott requested a state administrative hearing under Tennessee procedures.
- Before the hearing began, Elliott filed a federal action alleging race discrimination and seeking relief under Title VII and Reconstruction-era civil rights statutes, including 42 U.S.C. § 1983.
- A Tennessee administrative law judge found the proposed discharge was not racially motivated; a university official affirmed on administrative appeal.
- Elliott did not seek review of the administrative decision in Tennessee courts and instead pursued his federal claims.

## Issues

1. Whether 28 U.S.C. § 1738 requires federal courts to give preclusive effect to unreviewed state administrative factfinding.
2. Whether unreviewed state administrative findings can preclude a federal Title VII action.
3. Whether, as a matter of federal common law, unreviewed state administrative factfinding can preclude claims under § 1983 and related Reconstruction civil rights statutes when the agency acted judicially and the parties had an adequate opportunity to litigate.

## Decision

- The Court held that § 1738 does not apply to unreviewed state administrative findings because it governs state court records and judicial proceedings, not agency determinations.
- The Court held that unreviewed state administrative findings do not preclude Title VII claims; Congress intended federal courts to adjudicate Title VII claims without being bound by such unreviewed agency determinations.
- The Court held that, for § 1983 and related Reconstruction statutes, federal common law requires giving preclusive effect to state agency factfinding when the agency acted in a judicial capacity, the parties had an adequate opportunity to litigate, and state courts would give the findings preclusive effect.
- Disposition: affirmed as to the Title VII claim (no preclusion); reversed as to the § 1983-type claims (preclusion), leaving summary judgment appropriate on those claims.

## Legal Principles

- 28 U.S.C. § 1738 mandates full faith and credit for state court judgments, but does not itself govern unreviewed state administrative adjudications.
- Title VII’s enforcement scheme reflects congressional intent against treating unreviewed state administrative findings as claim- or issue-preclusive in subsequent federal Title VII litigation.
- For § 1983 and related Reconstruction civil rights statutes, ordinary preclusion principles may apply through federal common law to unreviewed state administrative factfinding, keyed to: (1) a judicial-type administrative process, (2) resolution of disputed factual issues, (3) an adequate opportunity to litigate, and (4) the preclusive effect the state’s own courts would assign.
- A party’s failure to seek available state-court review can leave adverse administrative factfinding binding for later § 1983-type federal litigation when state law would treat it as preclusive.

## Conclusion

The Court distinguished Title VII from § 1983-type claims: unreviewed state administrative findings cannot bar a federal Title VII action, but they can preclude § 1983 and related claims under federal common law when the agency proceeding was adjudicative, the parties fully litigated the facts, and state law would treat those findings as binding.


Univ. of Tenn. v. Elliott, 478 U.S. 788 (1986)