Carter v. Glenn, 1:13-cv-00079

Carter, a pro se inmate, filed a §1983 action in the Eastern District of Arkansas against Officer Glenn, Sgt. Downings, and Sgt. Stewart for retaliation and discrimination.
Carter alleges Glenn issued a false disciplinary report on August 25, 2012 in retaliation for requesting a grievance form; Downings allegedly retaliated on October 22, 2013 when Carter tried to submit a grievance; Steward allegedly retaliated with false disciplinary charges on October 30, 2012.
Carter pursued relief through the Arkansas Claims Commission, prompting Defendants to move to dismiss based on res judicata and collateral estoppel.
The court discusses Rule 8(a)(2) and Twombly’s plausibility standard for stating a claim.
The court applies Steffen v. Housewright to examine collateral estoppel and explains the four elements required for collateral estoppel.
The court finds Carter’s claims were not actually litigated in the prior proceeding because the Arkansas Claims Commission letter states federal court relief was required, not a binding prior adjudication.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether res judicata bars Carter's claims	Carter asserts claims were not actually litigated in a prior action.	Defendants contend prior Arkansas Claims Commission actions preclude relitigation.	Res judicata does not bar; not actually litigated.
Whether the complaint states a plausible claim under Twombly	Carter alleges actionable retaliation and discrimination.	Complaint lacks plausible factual allegations to show entitlement to relief.	Claims deemed not sufficiently pled to state a plausible claim at this stage.
Whether the Arkansas Claims Commission record supports collateral estoppel	Record shows prior adjudication of issues in federal court.	Record shows issues were not actually litigated and thus collateral estoppel does not apply.	Record shows issues were not actually litigated; collateral estoppel not established.
Whether the retaliation claim against Downings should be dismissed	Downings engaged in retaliatory conduct against Carter.	Record insufficient to show adjudication of the motion to dismiss.	Motion to dismiss the Downings retaliation claim denied at this stage; not yet dismissed on that basis.

Steffen v. Housewright, 665 F.2d 245 (8th Cir. 1981) (collateral estoppel four elements)
Haize v. Hanover Ins. Co., 536 F.2d 576 (3d Cir. 1976) (four-element collateral estoppel test)
Lawlor v. National Screen Service Corp., 349 U.S. 322 (1955) (collateral estoppel principles)
United States v. Utah Construction & Mining Co., 384 U.S. 394 (U.S. 1966) (precludes relitigation after final judgment)
In re Piper Aircraft Distribution System Antitrust Litigation, 551 F.2d 213 (8th Cir. 1977) (collateral estoppel application discussion)
Tidewater Oil Company v. Jackson, 320 F.2d 157 (10th Cir. 1963) (collateral estoppel doctrine guidance)
Twombly, 550 U.S. 544 (S. Ct. 2007) (pleading standard: plausible claim, not mere allegations)