Senior Accountants, Analysts & Appraisers Ass'n v. City of Detroit

The issue in this case is limited to the consideration of whether an unappealed determination by the Michigan Employment Relations Commission that plaintiff is not entitled to "back pay” for a determined unfair labor practice operates as collateral estoppel to the subsequent maintenance of a suit in circuit court to recover the same reimbursement as "damages” for breach of contract.

We hold that plaintiffs are barred from suing for "damages” under a breach of contract theory by the doctrine of collateral estoppel because the questions of fact necessary for determination of "damages” by the…