Emily Roseberry v. North Slope Borough School District and North Slope Borough School District Board of Education, 568 P.3d 338

Emily Roseberry, former principal of Qargi Academy (a charter school), alleged the superintendent overstepped her authority and violated the school's contract, bylaws, and Alaska statutes.
Roseberry was terminated after reporting alleged misconduct by the superintendent to internal authorities and a professional commission.
Roseberry first sued in federal court, raising federal civil rights and state whistleblower claims. The federal court dismissed the federal claims with prejudice and declined to exercise jurisdiction over the state whistleblower claim.
Roseberry then sued in Alaska state court, raising the whistleblower claim and three new state-law claims: intentional interference with contract, negligent supervision, and defamation.
The superior court dismissed all state claims as precluded by the prior federal court proceedings; Roseberry appealed that decision.
The Alaska Supreme Court reviewed whether the superior court correctly applied issue and claim preclusion (i.e., res judicata/collateral estoppel).

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Roseberry's Whistleblower Act claim is barred by issue preclusion from the prior federal judgment	The federal court’s finding under the First Amendment is not dispositive of the Whistleblower Act’s "public concern" standard	The federal court decided the "public concern" issue; relitigation is barred	Not barred – definitions of "public concern" differ between federal First Amendment and state Whistleblower Act
Whether additional state-law claims (interference, negligent supervision, defamation) are barred by claim preclusion as they could have been brought in federal court	The federal court dismissed federal claims early and would not have exercised jurisdiction over new state claims	Could have brought them in federal court; failure to do so bars re-litigation	Not barred – federal court would have declined supplemental jurisdiction, so state court can hear them

Garcetti v. Ceballos, 547 U.S. 410 (First Amendment protection for public employees' speech, defining "public concern")
Connick v. Myers, 461 U.S. 138 (Defines scope of "public concern" for First Amendment employment cases)
Taylor v. Sturgell, 553 U.S. 880 (Federal common law governs preclusive effect of federal-court judgments)
Patterson v. Walker, 429 P.3d 829 (Alaska standard for reviewing motions to dismiss and preclusion)
Methvin v. Bartholomew, 971 P.2d 151 (Distinction between protected activity under First Amendment and Alaska Whistleblower Act)
Thomas v. State, 377 P.3d 939 (Elements necessary for retaliation claims under First Amendment and Whistleblower Act)
Plumber v. Univ. of Alaska Anchorage, 936 P.2d 163 (Res judicata/claim preclusion under Alaska law)