Officer could not collaterally attack his termination, previously upheld in state courts, by filing a suit in Federal Court. Employee must exhaust his administrative remedies before bringing a federal civil rights suit in state court system. Discharged employee who lost state appeal cannot challenge his termination in a federal civil rights suit. Pre-hearing suspension periods are discipline if back pay not awarded, and may be appealed. Illinois Supreme Court holds public employees have a right to appeal disciplinary suspensions, even if statute says they don't.
Federal judge criticizes the large volume of petty disciplinary claims that clog the federal courts.
Court may order reinstatement but cannot require chief to assign reinstated subordinate in former position. Pennsylvania holds that a written reprimand may not be appealed without statutory authority. Woods v. Civil Service Cmsn. Punishment not appealable under civil service laws could be attacked through arbitration. Bergen Co. Law Enforcement Group v.