Anderson v. Vanguard Car Rental USA Inc.
2011 Fla. App. LEXIS 6659
| Fla. Dist. Ct. App. | 2011Background
- Anderson filed a federal complaint against Vanguard on August 11, 2005, initially including state-law claims, later dismissed without prejudice.
- On August 10, 2007, Anderson filed a second amended federal complaint with five counts, three of which were Florida law claims.
- On July 6, 2007, Anderson filed a Florida circuit court action based on the same facts, containing four of the same counts as the federal complaint.
- Vanguard moved in state court on August 31, 2007 to dismiss or stay, arguing the cases involved identical parties and issues to the federal case.
- Anderson voluntarily dismissed the state-law counts in the federal case on November 7, 2007; the federal case later proceeded on federal claims only.
- On February 29, 2008, the federal court dismissed the federal claims with prejudice for failure to state a claim; the Eleventh Circuit affirmed in 2009; certiorari was denied by the Supreme Court.
- In November 2009, Vanguard moved to lift the stay and dismiss the Florida action; the trial court granted dismissal with prejudice on res judicata grounds, which Anderson challenged.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether the federal judgment on merits barred state claims in Florida. | Anderson argues the federal judgment did not reach state-law merits due to voluntary dismissal. | Vanguard contends the federal judgment precludes state claims under res judicata. | Reversed; no merits judgment on state claims existed in the federal order. |
| Whether voluntary dismissal of state-law claims in federal court precludes Florida res judicata. | Voluntary dismissal of state-law claims means no final merits adjudication, so not barred. | Defendant asserts res judicata applies since state claims could have been pursued in federal court. | Held in favor of Anderson; voluntary dismissal does not bar Florida state-law claims. |
| Whether the federal and state actions involved identical causes of action. | State-law claims arise from the same facts as federal claims. | Key question is whether the state and federal claims are identical across sovereignties. | Held that state and federal causes of action are not identical; sovereign difference precludes identity. |
Key Cases Cited
- Andujar v. Nat'l Prop. & Cas. Underwriters, 659 So.2d 1214 (Fla. 4th DCA 1995) (federal and state claims are not identical when arising under different sovereigns)
- Dalbon v. Women’s Specialty Retailing Grp., 674 So.2d 799 (Fla. 4th DCA 1996) (federal court final judgment on merits governs related pendent-state claims)
- Bosdorf v. Sinnamon, 804 So.2d 510 (Fla. 3d DCA 2001) (Rule 41 dismissal in federal court may not bar claims in a different court)
- Semtek Int'l Inc. v. Lockheed Martin Corp., 531 U.S. 497 (2001) (voluntary dismissal with prejudice may not preclude later action in a different forum)