Charleston v. McCarthy, No. 20-2676 (8th Cir. 2021)
Annotate this CaseThe Eighth Circuit affirmed the district court's adverse grant of summary judgment on plaintiff's political retaliation claim related to disciplinary measures and his ultimate termination from the Sheriff's Office. The court concluded that there was no error in the district court's determination that collateral estoppel barred plaintiff from pursuing his political retaliation claim based on those issues he raised in his termination appeal; the district court could give the Iowa Civil Service Commission's determination preclusive effect; and plaintiff failed to make a prima facie case that his two-day suspension was political retaliation because he could not establish a causal connection between the suspension and his political campaign.
Court Description: [Shepherd, Author, with Gruender and Benton, Circuit Judges] Civil case - Civil rights. For the court's prior opinion in the matter, see Charleston v. McCarthy 926 F.3d 982 (8th Cir. 2019). The district court did not err in determining that the doctrine of collateral estoppel barred plaintiff's claim that he was terminated in retaliation for his campaign for the office of sheriff; the district court could give the Iowa Civil Service Commission's determination preclusive effect; plaintiff failed to make a prima facie case that his two-day suspension was political retaliation as he could not establish a causal connection between the suspension and his political campaign.
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