Alexander v. DeSoto County Soil and Water Conservation District, 3:15-cv-00179

Plaintiff Effort Alexander owns property in Horn Lake containing a dam/project originally subject to a 1956 easement involving the DeSoto County Soil and Water Conservation District (the District).
Alexander previously sued the District in 2014 (Alexander I) alleging the District failed to maintain/remove the Project and sought damages and removal; that suit was dismissed with prejudice as time-barred and affirmed by the Fifth Circuit.
In October 2015 Alexander filed a new pro se § 1983 action against the District and other local/state entities alleging deprivation of Fourteenth Amendment rights based on the same dam/easement conduct and sought damages and declaratory/mandamus-type relief to force removal and restoration.
The District moved to dismiss or for summary judgment, supplying extrinsic exhibits; the court treated the motion as one for summary judgment under Rule 56.
The District argued multiple defenses (res judicata, statute of limitations, judicial estoppel, lack of property interest, improper service); the court granted summary judgment solely on res judicata grounds and declined to reach the other arguments.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Alexander's § 1983 suit is barred by res judicata	Alexander contends his constitutional § 1983 claims were not raised in the prior suit and thus are new	District argues the new suit arises from the same nucleus of operative facts as Alexander I and the earlier final judgment bars relitigation	Granted — res judicata applies; summary judgment for District
Whether the prior dismissal was a final judgment on the merits	Alexander argued the prior case was dismissed on pleadings/motions, not merits	District relied on the March 2015 dismissal with prejudice and Fifth Circuit affirmance	Held that dismissal on statute-of-limitations grounds with prejudice is a final adjudication on the merits
Whether the claims in the new suit involve the same transaction/operative facts	Alexander claimed new constitutional theory; facts differ in characterization	District showed both suits arise from same continuing failure to assume responsibility for the Project/dam	Held the transactional test is satisfied — same nucleus of operative facts
Whether Alexander could or should have brought § 1983 claims earlier	Alexander argued constitutional claim was distinct and not previously raised	District argued plaintiff had actual or imputed awareness and the prior court had procedural mechanisms to hear such claims	Held plaintiff could/should have raised these claims in Alexander I; res judicata precludes relitigation

Allen v. McCurry, 449 U.S. 90 (establishing that final judgment on the merits precludes relitigation)
Celotex Corp. v. Catrett, 477 U.S. 317 (summary judgment burden-shifting principles)
Little v. Liquid Air Corp., 37 F.3d 1069 (resolving factual controversies in favor of the nonmoving party on summary judgment)
Norwegian Bulk Transp. A/S v. Int'l Marine Terminals P'ship, 520 F.3d 409 (summary judgment standard)
Davis v. Dallas Area Rapid Transit, 383 F.3d 309 (transactional test for claim preclusion)
Dorsey Trailers, Inc. v. 880 F.2d 820 (dismissal on statute of limitations as adjudication on the merits)