C.H. Robinson Worldwide, Inc. v. George Lobrano, Jr.
695 F.3d 758
8th Cir.2012Background
- Lobrano's employment with C.H. Robinson included a Management-Employee Agreement with a broad noncompete and Minnesota governing law.
- C.H. Robinson issued Lobrano stock vesting under restricted plans; post-employment, noncompete extended vesting by two years.
- Louisiana court voided the noncompete as overly broad under Louisiana law; no appeal by C.H. Robinson.
- C.H. Robinson filed Minnesota action, seeking various relief, including vesting implications; Lobrano moved to dismiss based on res judicata.
- District court in Minnesota dismissed Count VI on res judicata grounds but declined sanctions/fees; its ruling is appealed.
- This appeal centers on whether Louisiana judgment precludes Count VI and whether sanctions are warranted.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Does res judicata preclude Count VI? | Robinson argues Louisiana judgment bars Count VI. | Lobrano contends res judicata does not preclude or the claims differ. | Res judicata precludes Count VI. |
| Did Count VI arise from same transaction or occurrence as the Louisiana action? | Robinson contends not same transaction; broader scope. | Lobrano asserts Count VI related to vesting post-LA judgment and covenants. | Count VI arose from same transaction/occurrence. |
| Should sanctions/attorney's fees be imposed for the Minnesota action? | Robinson seeks sanctions/fees for res judicata missteps. | Lobrano argues no sanction given colorable defenses. | Sanctions and attorney's fees not warranted. |
Key Cases Cited
- Laase v. Cnty. of Isanti, 638 F.3d 853 (8th Cir. 2011) (de novo review of res judicata dismissal)
- Howard v. Green, 555 F.2d 178 (8th Cir. 1977) (res judicata is an affirmative defense)
- Potamitis v. Pittsburgh Plate Glass Co., 82 F.2d 472 (8th Cir. 1936) (res judicata raised on face of petition)
- Noble Sys. Corp. v. Alorica Cent., LLC, 543 F.3d 978 (8th Cir. 2008) (12(b)(6) dismissal based on res judicata when apparent on face of complaint)
- Quinn v. Ocwen Fed. Bank FSB, 470 F.3d 1240 (8th Cir. 2006) (materials attached to complaint for res judicata analysis)