The United States Court of Appeals for the Fifth Circuit has held that dismissal for failure to comply with the Administrative Procedure Act of a Title VII employment discrimination action brought by the Equal Employment Opportunity Co mission is res judicata as to an individual's subsequent private action based upon the same claim.
Jones v. Bell Helicopter Co., 614 F.2d 1389 (5th Cir. 1980).
John R. O'Keefe,
Civil Rights - Race Discrimination - Title VII of the Civil Rights Act of 1964 - Res Judicata - Individual Actions Subsequent to EEOC Actions,
Duq. L. Rev.
Available at: https://dsc.duq.edu/dlr/vol19/iss3/10