River Park, Inc. v. City of Highland Park (II)

Citation. 703 N.E.2d 883 (Ill. 1998)

Brief Fact Summary.

River Park, Inc. filed an action in federal district court. After the federal court complaint was dismissed, River Park filed a state court complaint. The state court held that River Park’s claims were barred by res judicata. The appellate court reversed, holding that the state court action was not barred by res judicata.

Synopsis of Rule of Law.

Res judicata may bar state law claims in an action brought in state court after a federal court complaint has been dismissed; the argument that res judicata should not bar the claims because they could not have been asserted in federal court is unavailing because a district court is not required to dismiss pending state law claims after dismissing the claim from which its original jurisdiction stemmed.

Facts.

River Park, Inc. filed an action in federal district court. The complaint alleged that the City of Highland Park violated 42 U.S.C. 1983 by depriving River Park of its property rights without due process of law. After the federal court complaint was dismissed, River Park filed a state court complaint. The state court held that River Park’s claims were barred by res judicata; the state appellate court reversed, holding that the state court action was not barred by res judicata. On appeal, River Park argued that res judicata should not bar its state law claims because those claims could not have been asserted in federal court, and the court would have lacked jurisdiction over those claims after it dismissed the 42 U.S.C. 1983 action.

Issue.

Did res judicata bar River Park’s state law claims ?

Held.

Yes. River Park’s claims were barred under the doctrine of res judicata by the dismissal of the federal lawsuit.

Discussion.

River Park’s state law claims were claims that could have been decided in the federal suit by the federal court exercising supplemental jurisdiction over claims that were part of the same case or controversy. River Park did not file state law claims in federal court so it was unknown if the federal court would have refused to exercise supplemental jurisdiction. However, federal courts have exercised supplemental jurisdiction under similar circumstances.