McConnel v. Travelers Indemnity Co

Brief Fact Summary.

Man injured in a car crash attempts to split his claim and bring one suit in state court and the other in federal court.

Synopsis of Rule of Law.

Under Louisiana law a plaintiff may not split their claim between state and federal court.

Facts.

Plaintiffs, two Louisiana residents, were involved in an accident and brought suit against Defendant Travelers Indemnity Co. for medical expenses. Mr. and Mrs. McConnell filed two separate suits in federal court seeking damages. Mr. McConnell requested $85,000 and $352.50 to cover medical expenses. Almost two years later Mr. McConnell filed a suit in state court for his medical expenses. Defendant Travelers filed a motion for summary judgement alleging that Mr. McConnell impermissibly split his claims between state and federal court. While Defendant Traveler’s motion for summary judgement was pending in state court, Mr. McConnell voluntarily dismissed his state claims with prejudice, and the district court denied Defendant Traveler’s motion. Defendant Travelers then filed a motion for summary judgement in federal court arguing that Mr. McConnell could only pursue his claim for personal injuries by amending his state claim, but because he dismissed them in state court with prejudice, he had in fact dismissed his whole claim. Travelers argued this dismissal with prejudice was a final judgement and that the case in federal court was barred by res judicata.

Issue.

May a plaintiff in Louisiana split his claim between state and federal court?

Held.

No, a plaintiff under Louisiana law may not split their claim between state and federal court. The holding below is affirmed.

Discussion.

1. Louisiana case law states that a plaintiff may not split claims for property damage and personal injuries arising from the same incident.
2. While tort law in this case creates a biased outcome, it must be applied as it is written while following res judicata.
3. The holding below is affirmed.