Williams v. City of Jacksonville Police Dept.

Brief Fact Summary.

Plaintiff sued Defendants for state and federal law violations in state court. Defendants removed the case to federal court and moved for summary judgment.

Synopsis of Rule of Law.

An issue has been previously determined, for purposes of collateral estoppel, when the same issue in a prior action was raised and actually litigated, material and relevant to the disposition, and necessary and essential to the resulting judgment.

Facts.

Williams (Plaintiff) sued the City of Jacksonville Police Department, Officer Billy Houston, and Officer Earl Burkhart (Defendants) in state court for violations of state and federal law following a traffic stop. Defendants removed the case to federal court and moved for summary judgment.

Issue.

Is the Plaintiff’s claim barred by res judicata? Is the Plaintiff’s claim barred by collateral estoppel?

Held.

No, Plaintiff’s claims are not barred by res judicata. Yes, Plaintiff’s claims are barred by collateral estoppel. Reversed and remanded.

Discussion.

The Court determined that the Plaintiff’s state law claims were not barred by res judicata because the claims were not litigated by the federal court, but instead dismissed without prejudice. However, the Court determined that the Plaintiff’s state law claims of negligence and false arrest were barred by collateral estoppel because the federal court had made a determination on these same issues as part of their reason for granting summary judgment for the Defendants on the federal law claims.