Southfield Education Ass'n v. Southfield Board of Education

CLAY, Circuit Judge.

Plaintiff Southfield Education Association filed two lawsuits, one in state court, and then a second in federal court pursuant to 42 U.S.C. § 1983, alleging that Defendant Southfield Board of Education violated the due process rights of twenty-three teachers laid off during the 2010-2011 academic school year. After the state court dismissed Plaintiffs due process claim, the district court granted Defendant’s motion to dismiss based on res judicata. Plaintiff argues that because the due process claim asserted in state court was based on the Michigan Constitution whereas the…