In the case of University of Tennessee et al. v. Elliott, 1985, the Supreme Court ruled that an unreviewed state administrative proceeding's findings have preclusive effect in a Title VII action in federal court if those proceedings meet the criteria for giving them such effect under state law. The respondent, Charles Elliott, filed charges against his employer with both the Equal Employment Opportunity Commission (EEOC) and Tennessee Human Rights Commission claiming racial discrimination after being fired from his job at a university agricultural experiment station. After losing at a hearing before an Administrative Law Judge (ALJ), he sued in Federal District Court alleging violations of Title VII and 42 U.S.C §1981 which prohibits racial discrimination in making contracts. The District Court granted summary judgment to defendants based on res judicata - meaning that since it had already been decided by ALJ there was no need for further trial - but this decision was reversed by Appeals court stating that unreviewed administrative decisions do not prevent subsequent litigation under Title VII or Section 1981 claims.

In the dissenting opinion for University of Tennessee et al. v. Elliott, Justice White disagreed with the majority's decision to allow administrative findings by state agencies to have preclusive effect in Title VII cases. He argued that this ruling contradicted previous Supreme Court decisions which held that unreviewed administrative determinations do not preclude de novo judicial proceedings under federal statutes providing private causes of action. Furthermore, he contended that Congress did not intend for such a result when it enacted Title VII and other civil rights laws designed to protect individuals from discriminatory practices. He also expressed concern about potential inconsistencies between different states' procedures and standards for adjudicating discrimination claims, which could lead to unequal treatment of litigants depending on where they live or work.