Dawn L. Huntley v. State of Rhode Island
2013 R.I. LEXIS 56
| R.I. | 2013Background
- Huntley, a 56-year-old African-American prosecutor, alleges a pattern of sex and race discrimination and denial of promotion and raises during 1999–2008.
- She filed an internal grievance in 2006 (unfounded) and was terminated in July 2008 after returning from medical leave.
- In November 2008 she filed a charge with the Rhode Island Commission for Human Rights; received a right-to-sue notice in November 2010 with a 90-day filing window.
- On April 30, 2010, Huntley filed a pro se federal complaint against the State AG’s Office; amended to drop many individuals in favor of state entities and certain officials; federal dismissal occurred October 4, 2010, without explicit prejudice noted.
- On January 31, 2011 she filed a state Superior Court action asserting FEPA, RICRA, and WPA claims; March 24, 2011 amended the complaint to add Coyne, Goulart, Chafee, Kilmartin, and Raimondo.
- The State moved to dismiss or for summary judgment in July 2011 asserting res judicata; the Superior Court denied the motions; the Supreme Court granted certiorari to review res judicata and relation-back issues.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Does the federal judgment bar Huntley’s state action via res judicata? | Huntley contends the federal dismissal was not on the merits (lack of jurisdiction) and thus not a final merits judgment. | State asserts the federal dismissal is a final judgment on the merits and precludes the state action. | Yes; the federal judgment bars the state action due to finality and identity of parties and issues. |
| Was the federal dismissal a merits adjudication under Rule 41(b)? | Dismissal was jurisdictional, not merits-based, so res judicata should not apply. | Dismissal operates as a merits adjudication regardless of stated grounds; Huntley had notice and did not oppose. | Dismissal operated as a merits adjudication; res judicata applies. |
| Did the amended complaint relate back to the original for adding Coyne and Goulart? | Amendment relates back because filed before any responsive pleading and search dictates timely addition. | Amendment was not a mere mistake; relation back should be assessed strictly and may be time-barred. | The amended complaint related back; adding Coyne and Goulart was timely. |
| Are RICRA and WPA claims timely given statutes of limitations and relation back? | WPA and RICRA claims are not subject to the 90-day notice window and thus timely. | Res judicata bars the federal-related claims, and relation back does not salvage untimely aspects. | Court did not reach separate timeliness due to res judicata; preclusion applies. |
Key Cases Cited
- Massachusetts School of Law at Andover, Inc. v. American Bar Association, 142 F.3d 26 (1st Cir. 1998) (due process suffices for full and fair opportunity to litigate)
- Federated Department Stores, Inc. v. Moitie, 452 U.S. 394 (U.S. 1981) (dismissal for failure to state a claim is a merits adjudication)
- AVX Corp. v. Cabot Corp., 424 F.3d 28 (1st Cir. 2005) (dismissal for failure to oppose motion treated as merits adjudication)
- Acevedo-Villalobos v. Hernandez, 22 F.3d 384 (1st Cir. 1994) (merits adjudication concept under Rule 41(b))
- Bell v. Hood, 327 U.S. 678 (U.S. 1946) (notice and due process considerations in judgments)
- Angel v. Bullington, 330 U.S. 183 (U.S. 1947) (jurisdictional vs merits in dismissals)
- Lennon v. Dacomed Corp., 901 A.2d 582 (R.I. 2006) (privity for identity of parties in res judicata)
- DiBattista v. State, 808 A.2d 1081 (R.I. 2002) (identity of issues in res judicata)
- Carrozza v. Voccola, 962 A.2d 73 (R.I. 2009) (identity of issues and transaction scope)
- Bossian v. Anderson, 991 A.2d 1025 (R.I. 2010) (defining scope of res judicata)