Albert Fields, Jr. v. City of Salem Housing Authorit
710 F. App'x 567
| 3rd Cir. | 2017Background
- Fields was a tenant in a HUD-subsidized Housing Authority unit; his lease required accurate income reporting and a $50 minimum monthly rent under HUD regs.
- In 2013 the Housing Authority determined Fields underreported income, assessed $2,521 in arrears, raised his monthly rent to $308 (retroactive), and notified him of the right to a grievance hearing and of termination for nonpayment.
- The Housing Authority sued in New Jersey state court; the state court entered judgment for possession unless Fields paid $3,703; Fields did not pay and was ultimately removed after his motions to vacate were denied.
- Fields filed a § 1983 action in federal court alleging due process violations, unlawful retroactive rent increases, and retaliatory eviction; the District Court screened and dismissed several counts and allowed Fields to proceed only on claims against two employees (Loyle and Dickerson) alleging denial of a grievance hearing.
- The District Court granted summary judgment to Loyle and Dickerson on issue- and claim-preclusion grounds based on the prior state-court adjudications; the court also denied Fields’ motion for reconsideration. The Third Circuit affirmed.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether federal suit may proceed on claim that officials denied required grievance hearing before eviction | Fields: Housing Authority/officials failed to provide informal/formal grievance hearing as required by HUD regs, violating due process | Defs: Issue already litigated and decided against Fields in state court; preclusion bars relitigation | Court: Issue preclusion applies; summary judgment for defendants affirmed |
| Whether retaliatory eviction claim (related to 2013 eviction) may be litigated in federal court | Fields: He was retaliated against for requesting a hardship exemption; seeks to pursue retaliation claim | Defs: Claim preclusion/claim waiver — related claims were or could have been adjudicated in state proceedings and some were dismissed in state court; Fields also abandoned some claims in federal screening | Court: Retaliation claim barred by claim preclusion or deemed withdrawn; not allowed |
| Whether District Court erred in dismissing/screening earlier counts under 28 U.S.C. § 1915(e) | Fields: (implicit) federal claims should survive screening | Defs: Screening dismissal proper; some claims dismissed without prejudice, others with prejudice based on prior state rulings or procedural defects | Court: Screening and dismissals were proper and entitled to full faith and credit |
| Whether motion for reconsideration should have been granted | Fields: sought reconsideration of summary judgment denial of his motion | Defs: No intervening change, new evidence, or clear error — reconsideration improper | Court: Denial of reconsideration affirmed (no basis to reopen) |
Key Cases Cited
- Alcoa, Inc. v. United States, 509 F.3d 173 (3d Cir.) (summary judgment standard)
- Elkadrawy v. Vanguard Group, Inc., 584 F.3d 169 (3d Cir.) (plenary review of preclusion)
- Lubrizol Corp. v. Exxon Corp., 929 F.2d 960 (3d Cir.) (purpose of preclusion doctrines)
- Montana v. United States, 440 U.S. 147 (U.S.) (objectives of res judicata and issue preclusion)
- Allen v. McCurry, 449 U.S. 90 (U.S.) (federal courts give preclusive effect to state court judgments)
- Kost v. Kozakiewicz, 1 F.3d 176 (3d Cir.) (preclusion doctrines apply in federal and state courts)
- Olivieri v. Y.M.F. Carpet, Inc., 897 A.2d 1003 (N.J.) (elements of issue preclusion under New Jersey law)
- Watkins v. Resorts International Hotel & Casino, Inc., 591 A.2d 592 (N.J.) (scope of claim preclusion)
- Max’s Seafood Café v. Quinteros, 176 F.3d 669 (3d Cir.) (standard for motions for reconsideration)
- Edmundson v. Borough of Kennett Square, 4 F.3d 186 (3d Cir.) (full faith and credit to state judgments)