Constance Ray v. Birmingham City Board of Education Dr. Walter Harris, President of the Birmingham Board of Education

RONEY, Chief Judge:

Defendant, Birmingham City Board of Education (“Board”), appeals an order granting plaintiffs motion for summary judgment on her Section 1983 procedural due process claim for termination of her employment as a school principal. Relying on an Alabama court decision that would indicate plaintiff had been improperly terminated under state law, the district court applied the doctrine of offensive collateral estoppel, and held that the defendant was barred from litigating the propriety of plaintiff’s contract termination and transfer. Because the district court applied state law…