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Morel v. American Building Maintenance Co.
Citation: 124 F. App'x 671Docket: No. 03-9327
Court: Court of Appeals for the Second Circuit; January 26, 2005; Federal Appellate Court
The judgment of the district court from November 4, 2003, which granted summary judgment to American Building Maintenance Company based on res judicata and collateral estoppel, is vacated. The case is remanded for further proceedings. Pro se plaintiff Marcos A. Morel appealed this decision, arguing that his employment discrimination claims under Title VII had been wrongly precluded due to a prior adverse labor arbitration decision under a collective bargaining agreement (CBA). The appellate court reviewed the district court's summary judgment de novo, referencing the case of Alexander v. Gardner-Denver Co., which established that federal courts should not give preclusive effect to arbitral resolutions of federal statutory claims. The court noted that it has consistently held that a negative arbitration decision does not bar a subsequent Title VII action, highlighting that American Building Maintenance failed to address this precedent in its defense. While acknowledging that an adverse arbitral decision may still be relevant, the court emphasized that the burden is on the plaintiff to present strong evidence challenging the arbitral decision if it wishes to survive a motion for summary judgment. Since American Building Maintenance did not raise this argument in its motion, the district court did not have the opportunity to consider whether Morel could provide such evidence. Therefore, the appellate court vacated the previous judgment and mandated further proceedings to explore these issues.