Vairrun Strickland v. City of Markham

── Vairrun Strickland v. City of Markham ── Court: Court of Appeals for the Seventh Circuit Date: June 08, 2026 Category: General In the United States Court of Appeals For the Seventh Circuit ____________________ No. 24-3262 VAIRRUN STRICKLAND, Plaintiff-Appellant, v. CITY OF MARKHAM and ANTHONY MAZZIOTTA, Defendants-Appellees. ____________________ Appeal from the United States District Court for the Northern District of Illinois, Eastern Division. No. 1:22-cv-01419 — John J. Tharp, Jr., Judge. ____________________ ARGUED NOVEMBER 18, 2025 — DECIDED JUNE 8, 2026 ____________________ Before HAMILTON, ST. EVE, and KIRSCH, Circuit Judges. PER CURIAM. This appeal presents a new variation on a recurring scenario that requires federal courts in Illinois to split some fine hairs in the law of claim preclusion. A public employee believed his employer had taken action against him for unlawful reasons. He sought relief under both state and federal law, including the federal Constitution, and in both administrative proceedings and lawsuits. As we explain 2 No. 24-3262 below, principles of claim preclusion block most of plaintiff’s claims but not those under Title VII of the Civil Rights Act of 1964. Plaintiff Vairrun Strickland, an African American man, was fired from his job as a firefighter for the City of Markham, Illinois. Strickland first sued in state court challenging the administrative decision that led to his firing. He then filed this federal lawsuit against the City of Markham and the Fire Chief Anthony Mazziotta. This suit asserts civil rights claims under Title VII of the Civil Rights Act of 1964, the Fourteenth Amendment to the United States Constitution, and the Illinois State Officials and Employees Ethics Act. Strickland then voluntarily dismissed his lawsuit in state court. The federal district court then concluded that this entire federal suit is foreclosed by principles of claim preclusion based on the adverse administrative ruling under Illinois law. The district court granted summary judgment for the defendants on all claims. We affirm in part and vacate and remand in part. Federal law treats a state court’s judgment and a decision in an administrative proceeding differently for purposes of claim preclusion. Because the district court overlooked this threshold issue of federal law, it erred in entering summary judgment on Strickland’s Title VII claims. But this distinction does not alter the outcome on Strickland’s other claims, and the district court otherwise correctly applied the Illinois law of claim preclusion. I. Factual and Procedural Background Strickland worked as a firefighter for the City of Markham Fire Department for over a decade. In 2020, the Equal No. 24-3262 3 Employment Opportunity Commission interviewed Strickland during an investigation into discrimination claims brought by a former firefighter. In the interview, Strickland described race-based discrimination he had witnessed against the former firefighter and how Chief Mazziotta had failed to address it. Strickland alleged that after the interview, Chief Mazziotta and the Department retaliated against him by singling him out for minor disciplinary issues and denying him a promotion. In January 2021, the Department brought administrative charges against Strickland. After hearings on the charges, the Board of Fire and Police Commissioners terminated his employment in April 2021, finding that Strickland had lied to detectives during an arson investigation and had put Department employees at risk by coming to work while infected with COVID-19. The next month, Strickland filed a lawsuit in state court challenging the Board’s decision. The court remanded while