Manicki v. Zeilmann
United States Court of Appeals for the Seventh Circuit
443 F.3d 922 (2006)
Probationary police officer Mark Manicki (plaintiff), after witnessing a fight between two officers, was pressured by police chief Brian Zeilmann (defendant) to falsely report both officers as equally at fault; when Manicki refused, Zeilmann wrote to the city's Board of Fire and Police Commissioners claiming Manicki performed inadequately and should be fired, and the Board fired him without a hearing. Manicki first sued the Board and Zeilmann in Illinois state court claiming the Board violated his due-process rights by firing him without a hearing given Zeilmann's retaliatory letter, and lost; he then sued Zeilmann and the City of Ottawa (defendants) in federal court, alleging Zeilmann's retaliatory conduct violated his First Amendment rights. The district court dismissed on res judicata grounds, and Manicki appealed.
Whether res judicata bars a plaintiff from pursuing a claim in a new lawsuit if a claim by the plaintiff against the same party and involving the same operative facts was previously adjudicated.