Caton v. City of Pelham

Supreme Court of Alabama

Shelby County | 329 So. 3d 5 | Dec. 11, 2020


Plaintiff's Retaliatory-Discharge Claim Dismissed Due to Previous Misconduct Determination

Caton, a former police officer, sustained multiple injuries over his career, leading to various medical treatments and eventual disagreements with medical professionals. After a disagreement at Dr. Turnley's office, Caton was fired by the City for violating the City's code of conduct. Following his termination, his claim for unemployment benefits was denied due to work-related misconduct.

In 2017, Caton filed a complaint for worker's compensation for an injury he suffered in 2015, later amending the complaint to include a claim of retaliatory discharge. A settlement was reached for the worker's compensation but left the retaliatory discharge claim unresolved. A complication arose when a summary judgment motion by the City was improperly served to only one of Caton's two attorneys.

The court later granted the City's summary judgment based on the doctrine of collateral estoppel, citing Caton's previous unemployment-compensation proceedings. Caton appealed, arguing his right to a jury trial was violated. The court determined that the doctrine of collateral estoppel did not infringe on Caton's rights, emphasizing that Caton had previously had an opportunity to litigate his employment termination. Ultimately, the court affirmed the summary judgment in favor of the City.

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