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Paul Shields v. Bellsouth Advertising and Publishing Company, Inc.
Citations: 254 F.3d 986; 11 Am. Disabilities Cas. (BNA) 1716; 2001 U.S. App. LEXIS 13770; 2001 WL 687012Docket: 99-8307
Court: Court of Appeals for the Eleventh Circuit; June 19, 2001; Federal Appellate Court
Paul Shields appealed the dismissal of his wrongful termination suit against BellSouth Advertising and Publishing Company (BAPCO) based on Georgia's doctrine of collateral estoppel. The case arose after Shields sought unemployment benefits in Georgia, where a Superior Court determined that there was no evidence he was terminated due to his HIV-positive status. The federal district court dismissed Shields's lawsuit, which alleged wrongful termination under the Americans with Disabilities Act (ADA), concluding that the core issue of his claim had already been litigated in the state proceedings, which provided a full and fair hearing in compliance with federal due process standards. The Eleventh Circuit previously agreed with the district court regarding the adequacy of the state proceedings but left open whether Georgia law would bar Shields's claim due to collateral estoppel. The court certified this question to the Georgia Supreme Court, which ruled that the Superior Court's finding indeed barred Shields from re-litigating the reasons for his termination in a subsequent wrongful termination lawsuit. Consequently, the Eleventh Circuit affirmed the district court's decision, concluding that Shields's ADA claim was barred by collateral estoppel.