He talked to the EEOC. Months later, he was fired - now his case is back
A fired Illinois firefighter has revived his Title VII retaliation suit after the Seventh Circuit ruled an administrative board ruling cannot block federal claims.
On June 8, 2026, the Seventh Circuit held that the City of Markham, Illinois, and its fire chief cannot rely on a local disciplinary board's decision to shut down Vairrun Strickland's federal discrimination and retaliation claims. The ruling draws a clear line for HR teams running administrative hearings and federal civil rights cases at the same time: on its own, an unreviewed administrative decision cannot defeat a Title VII lawsuit.
Strickland, an African American man, worked as a firefighter for the City of Markham Fire Department for over a decade. In 2020, the Equal Employment Opportunity Commission interviewed him during an investigation into discrimination claims brought by a former firefighter. Strickland described race-based discrimination he had witnessed against the former firefighter and said Fire Chief Anthony Mazziotta had failed to address it.
Strickland alleges that, after the interview, the chief and the department retaliated by singling him out for minor disciplinary issues and denying him a promotion. In January 2021, the department brought administrative charges against him. After hearings, the Board of Fire and Police Commissioners terminated his employment in April 2021. The board found that he had lied to detectives during an arson investigation and that he had come to work while infected with COVID-19, putting department employees at risk.
Strickland challenged the board's decision in Illinois state court. The court remanded the matter while retaining jurisdiction and instructed the board to enter an amended decision with additional information. The board did so and again ordered him discharged in April 2022. Strickland then voluntarily dismissed his state court lawsuit and did not otherwise seek direct review of the amended decision.
He had already filed a federal lawsuit in March 2022, bringing race discrimination and retaliation claims under Title VII, an equal protection claim under the Fourteenth Amendment via Section 1983, and a state law claim under the Illinois State Officials and Employees Ethics Act. The federal district court granted summary judgment for the city and the chief, ruling that Illinois claim preclusion rules barred the federal suit because the board's decision had become final.
The Seventh Circuit, in a per curiam ruling, agreed only in part. The panel held that federal law treats state court judgments and state administrative rulings differently for preclusion purposes. Under U.S. Supreme Court precedent, an unreviewed state administrative proceeding cannot preclude a Title VII claim. Because Strickland's voluntary dismissal of his state court suit left the board's decision effectively unreviewed, the district court was wrong to use it to throw out the Title VII case.
The rest of the appeal went the other way. The panel affirmed dismissal of the Section 1983 equal protection claim and the Illinois ethics claim. It held that federal common law gives an administrative decision acting in a judicial capacity the same preclusive effect it would have in state court, and that Illinois preclusion rules barred those claims. The panel said Strickland could have raised the thrust of his discrimination and retaliation claims as defenses at the board hearing, or joined them with his state court challenge, and his voluntary dismissal of the state suit closed those doors.
For HR functions in public-sector workplaces where firings move through statutory boards, the ruling is a practical signal. When an employee has filed an EEOC charge or flagged a federal lawsuit, the sequence and choice of forum can decide whether a federal claim survives. The decision also underscores that cooperating with an EEOC investigation, even on behalf of another employee, sits at the centre of the kinds of activity Title VII's retaliation provisions are built around.
The case has been sent back to the district court for further proceedings on the Title VII claim.
