Ryan v. New York Telephone Co.

Edward Ryan (plaintiff) was fired from New York Telephone Co. (defendant) after security investigators Lauriano and Perrino (defendants) reported seeing him take company property, leading to petit larceny charges. Ryan's unemployment benefits were denied by a claims examiner for misconduct, and an administrative law judge (ALJ), after hearing testimony including from Ryan, upheld that denial, finding Ryan had removed company property without authorization; that finding was affirmed by the Unemployment Insurance Appeal Board and then the Appellate Division. While those appeals were pending, the criminal charges against Ryan were dismissed "in the interest of justice," and Ryan and his wife then filed a civil suit for false arrest, malicious prosecution, slander, and wrongful discharge; the defendants raised res judicata and collateral estoppel as defenses, the trial court dismissed that defense, and on appeal the Appellate Division certified the question to the Court of Appeals.