The U.S. Supreme Court case Astoria Federal Savings and Loan Association v. Angelo J. Solimino, 1990, revolved around the issue of whether a state administrative agency's decision that an employee was not unlawfully terminated due to age discrimination precluded further litigation on the same claim under federal law in court (the doctrine of res judicata). The plaintiff, Angelo J. Solimino, had initially filed his complaint with New York State Division of Human Rights which found no probable cause for his claim against Astoria Federal Savings and Loan Association. He then pursued the matter in federal court under Age Discrimination in Employment Act (ADEA). The Supreme Court held that unreviewed administrative determinations by state agencies do not have preclusive effect on ADEA claims brought before courts; therefore Mr. Solimino could proceed with his lawsuit despite losing at the state level.

In the dissenting opinion for Astoria Federal Savings and Loan Association v. Angelo J. Solimino, Justice Marshall disagreed with the majority's interpretation of Section 14(b) of Age Discrimination in Employment Act (ADEA). He argued that Congress intended to allow state proceedings to have preclusive effect only when they were consistent with federal law. The majority's decision, he believed, undermined this intent by allowing state decisions to bar subsequent federal claims even if those decisions violated ADEA standards. Furthermore, he contended that the Court failed to consider whether New York’s administrative procedures met minimum requirements necessary for issue preclusion under federal common law principles developed in United States v. Utah Construction & Mining Co., which requires a full and fair opportunity to litigate an issue before it can be given preclusive effect.