Being a defendant in a Dallas employment law case once is challenging enough, but what happens when a disgruntled employee’s claims are dismissed in federal court but he refiles a second suit in state court?
The answer depends on several factors, each of which must be examined in detail by the court in which the second action is filed.
Facts of the Case
A recent case began with the plaintiff former employee filing suit in federal court against the defendant former employer, asserting claims for both discrimination and a hostile work environment, as well as common law claims associated with the defendant’s alleged disclosure of certain information about him to two police departments. The federal court dismissed the plaintiff’s suit with prejudice.
The plaintiff then filed a separate complaint against the defendant in state court, asserting over a dozen claims, including claims for defamation, intentional infliction of emotional distress, invasion of privacy, negligence, intrusion on seclusion, public disclosure of private information, and unauthorized disclosure of mental health information. The defendant filed a motion for summary judgment based on res judicata. The trial court granted the motion, and the plaintiff appealed.
Resolution of the Issues
The Court of Appeals for the Fifth District of Texas at Dallas affirmed the trial court’s granting of summary judgment in the defendant’s favor. According to the court of appeals, the lower tribunal had correctly concluded that the plaintiff’s claims in the state law case were barred by the doctrine of res judicata. In so deciding, the appellate court acknowledged that the doctrine of res judicata prevented the re-litigation of both the plaintiff’s claims that were expressly made in the other lawsuit and matters so closely related to those claims that they should have been included in the earlier action.
In order for res judicata to apply in a given situation, the parties to the two legal actions must be the same or in privity with one another; the court in the other action must have had competent jurisdiction; the prior action must have been a final judgment on the merits; and both actions must have involved the same cause of action. Here, the parties were identical; the federal district court had competent jurisdiction; the claims were dismissed with prejudice; and the claims in the federal and state court actions arose from the same nucleus of operative facts and were thus the same claim for purposes of res judicata.
Get Legal Advice About Employment Law Issues in Dallas
Claims brought by current or former employees can take many different forms. If your business is facing a claim – or if you expect that you could soon be the target of a lawsuit or EEOC charge – you should talk to an experienced Dallas employment litigation attorney. At Key Harrington Barnes, our experienced Dallas employment law attorneys assist clients with a multitude of legal issues. Call us at 214-615-7925 to schedule an appointment to come in and speak with a member of our legal team about the issue facing your business.
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