Umberfield v. School District No. 11

In Umberfield v. School District No. 11, 185 Colo. 165, 522 P.2d 730 (1974), the Court held that res judicata barred a second proceeding before the Colorado Civil Rights Commission on a teacher's claims of religious discrimination when that claim had been fully heard by a Teacher Tenure Panel in the dismissal proceedings. The court stated: "Because Umberfield had a full adversary hearing before the Teacher Tenure Panel which had the power to determine all his claims of religious discrimination, we hold that the doctrine of res judicata operates as a bar to the relitigation of issues which Umberfield raised or could have raised in the hearing before that panel and on judicial review. . . . To hold otherwise could result in an anomalous situation where the same reviewing court would be compelled to affirm opposite results of the two administrative bodies. . . . To avoid this judicial inconsistency, the doctrine of res judicata must be applied to the subsequently filed proceeding before the Civil Rights Commission." (Umberfield v. School District, supra, 185 Colo. at 173-74, 522 P.2d at 734.)