CITY OF HIALEAH GARDENS, A MUNICIPAL CORPORATION, PETITIONER,
v.
JOSE PRIETO, JR. AND DEPARTMENT OF COMMERCE, DIVISION OF EMPLOYMENT SECURITY, RESPONDENTS
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The City of Hialeah Gardens appeals an unemployment compensation decision awarding benefits to a former police officer. The court holds that the officer's prior judicial admission that he resigned—established in circuit court litigation—precludes him from relitigating whether he was discharged in the unemployment compensation proceeding, applying the doctrine of estoppel by judgment.
No. The doctrine of estoppel by judgment precludes an employee from relitigating in unemployment compensation proceedings whether he resigned or was discharged when that issue was already litigated and decided in a prior circuit court action, even though the causes of action differ.
[1] Estoppel by judgment precludes parties from relitigating issues actually decided in a previous suit, even if the causes of action differ.
[2] A judicial finding that an employee resigned precludes the employee from later claiming in unemployment compensation proceedings that they were discharged.
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Join FLexlaw to unlock all legal intelligence“The equitable doctrine of estoppel by judgment precludes the parties from litigating in a second suit, issues which were actually decided in a previous suit even though the causes of action are different.”
Establishes the controlling legal principle that estoppel by judgment applies across different causes of action when the same issue was previously litigated
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Join FLexlaw to unlock all legal intelligenceJose Prieto, Jr. was employed as a police officer by the City of Hialeah Gardens and was suspended. Before a hearing could be held under the Police Of…
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PER CURIAM.
Petitioner employer appeals an order of the Industrial Relations Commission which affirmed the decision of the appeals referee that petitioner’s former employee is entitled to unemployment compensation benefits because he was discharged from his job.
Jose Prieto, Jr. was employed by the City of Hialeah Gardens as a police officer. A dispute arose between them and he was suspended. He was then advised that a hearing on this matter would be held pursuant to Section 112.531, Florida Statutes (1975).1 However, prior to the hearing, Prieto and the chief of police reached an agreement whereby Prieto would receive a letter of commendation in exchange for his resignation. The letter was offered and Prieto orally resigned. Shortly thereafter Prieto filed suit in the circuit court seeking to enjoin the City of Hialeah Gardens from violating his rights under Section 112.531, Florida Statutes (1975) and praying that he be reinstated. The cause was heard and the chancellor entered final judgment for the City based upon the finding that Prieto orally resigned his position. Prieto then filed for unemployment compensation benefits. The claims examiner disqualified him because he had resigned. Prieto appealed and the appeals referee reversed the disqualification determination of the claims examiner and found that Prieto was discharged. The City appealed the referee’s decision to the Industrial Relations Commission which entered an order affirming that decision. The City filed the instant petition for certiorari seeking review of this order. We reverse.
This cause is a classic example of when the doctrine of estoppel by judgment is to be applied. The equitable doctrine of estoppel by judgment precludes the parties from litigating in a second suit, issues which were actually decided in a previous suit even though the causes of action are different. See Gordon v. Gordon, 59 So. 2d 40 (Fla.1952); Smith v. Florida East Coast Railway Company, 151 So. 2d 70 (Fla. 3d DCA 1963); Hohweiler v. Hohweiler, 167 So. 2d 73 (Fla. 2d DCA 1964).
As of necessity the issue of whether Prieto resigned or was discharged had and was litigated in the suit he brought in the circuit court. In that action the chancellor found that he, in fact, resigned. Thus, Prieto was precluded from litigating this same issue in the unemployment compensation proceedings. Accordingly, the Industrial Relations’ order affirming the decision of the appeals referee is reversed and the cause is remanded to the commission to enter an order reinstating the determination of the claims examiner that Prieto resigned and, therefore, is disqualified from receiving unemployment compensation benefits.
Certiorari granted.
. Police Officers’ Bill of Rights.
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Bd. OF Cnty. Comm'rs OF Dade Cnty. v. Eagle Fam. Disc. Stores, Inc., 380 So. 2d 486 (Fla. 3d DCA 1980)…jurisdiction has decided the exact question. Standard Accident Ins. Co. v. Simpson, 151 Fla. 564, 10 So. 2d 85 (1942). Therefore, Dade County is estopped by judgment from litigating the same issue in a state court. City of Hialeah Gardens v. Prieto, 353 So. 2d 200 (Fla. 3rd DCA 1977); and we concur with the trial court’s determination that there were no genuine issues to be tried. Affirmed.…
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Horan v. Horan, 464 So. 2d 224 (Fla. 4th DCA 1985)…ivocal judgment of contempt, the doctrine of estoppel by judgment would have precluded the husband from relitigating the same claim. See generally, Seaboard Coastline Railroad Co. v. Cox, 338 So. 2d 190 (Fla.1976); City of Hialeah Gardens v. Prieto, 353 So. 2d 200 (Fla. 3d DCA 1977); Zurich Insurance Co. v. Bartlett, 352 So. 2d 921 (Fla. 2d DCA 1977). However, estoppel by judgment is inapplicable in this ease because of the inconclusiveness of the “contempt judgment.” It expressly left the husband’s claim unr…
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Nat'l Union Fire Ins. Co. v. Scandia OF Hialeah, Inc., 414 So. 2d 533 (Fla. 3d DCA 1982)…v. Cox, 338 So. 2d 190 (Fla.1976); Tuz v. Edward M. Chadbourne, Inc., 310 So. 2d 8 (Fla.1975); Board of County Commissioners of Dade County v. Eagle Family Discount Stores, Inc., 380 So. 2d 486 (Fla. 3d DCA 1980); City of Hialeah Gardens v. Prieto, 353 So. 2d 200 (Fla. 3d DCA 1977); Simco Operating Corporation v. City National Bank of Miami Beach, 341 So. 2d 232 (Fla. 3d DCA 1977), cert. denied, 348 So. 2d 952 (Fla.1977). National Union further contends that because appellees could not prove some profit pri…
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- Sebastian v. THE City of Miami (Fla. 3d DCA 2020)
- Smith v. Fla. E. Coast Ry. Co., 151 So. 2d 70 (Fla. 3d DCA 1963)
- Hohweiler v. Hohweiler, 167 So. 2d 73 (Fla. 2d DCA 1964)