Nelson v. Emerald People's Utility District

This case involves two issues. The first is whether, under the facts of this case, an unemployment compensation decision by the Employment Division should be given preclu-sive effect in a subsequent civil action. The second issue is whether federal law governs the degree of proof and standard of conduct necessary for an award of punitive damages in a 42 USC § 1983 (1988) 1 civil rights action. On the first issue, we conclude that, because of lack of identity of issues, the agency’s decision should not have been given preclusive effect. On the second issue, we conclude that federal standards…