Can a plaintiff bring an amended federal complaint in response to the dismissal of her state sexual harassment claim?

^1. Sheffield challenges only the dismissal of her Title VII claims. Any challenge to the dismissal of any other claim has therefore been abandoned. Norton v. Sam's Club, 145 F.3d 114, 117 (2d Cir. 1998).

^2. Sheffield's amended federal complaint does add individual defendants not named in her state complaint. Even if Sheffield were to advance an argument that this renders preclusion principles inapplicable, we would nevertheless affirm the dismissal of the claims against the individual defendants because Title VII does not provide for individual liability. Spiegel v. Schulmann, 604 F.3d 72, 79 (2d Cir. 2010) (per curiam).

^3. Sheffield contends that the state court committed legal errors in so doing. Whether it did or not, "[t]he policy against relitigation of adjudicated disputes is strong enough generally to bar a second action even where further investigation of the law or facts indicates that the controversy has been erroneously decided, whether due to oversight by the parties or error by the courts." Reilly v. Reid, 379 N.E.2d 172, 175 (1978). As the district court explained in its opinion, the proper course was to appeal the state court's decision rather than to seek to restart the case in federal court.

^4. N.Y. C.P.L.R. 3211(a) provides, in pertinent part: