Fundamentalist Church of Jesus Christ of Latter-Day Saints v. Horne
698 F.3d 1295
10th Cir.2012Background
- FLDS Association filed a federal suit in Oct. 2008 seeking declaratory and injunctive relief regarding the UEP Trust modification and administration.
- Plaintiffs alleged six claims: federal constitutional, state constitutional, RLUIPA, and injunction-related relief concerning the UEP Trust.
- While federal case was pending, FLDS filed an extraordinary writ petition in Utah Supreme Court in Oct. 2009 seeking similar relief.
- Utah Supreme Court dismissed the petition, holding the claims were barred by laches due to nearly three-year delay and reliance on Trust modification.
- After Lindberg, the federal district court granted TRO and then a preliminary injunction in Feb. 2011, but the district court found no laches and proceeded.
- Defendants appealed, challenging preclusion; the district court did not certify the Utah Supreme Court’s Lindberg ruling as controlling before deciding the injunction.]
- The Tenth Circuit certified a question to the Utah Supreme Court about whether a laches-based dismissal in extraordinary writ proceedings is a merits decision for res judicata purposes, which Utah answered in Oct. 2012.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether Lindberg dismissal on laches is a merits decision for res judicata. | FLDS argues Lindberg was not merits-based and should not preclude federal action. | Wisan/Lindberg ruling is merits-based, precluding subsequent claims. | Yes; Lindberg is a merits decision, precluding later action. |
| Whether Utah law laches precludes federal claims under § 1738. | FLDS contends federal courts should not adopt Utah laches as preclusion. | Utah laches validly bars claims; § 1738 requires respect for state preclusion. | Yes; Utah laches precludes in federal court under § 1738. |
| Whether the FLDS Association’s claims are barred by res judicata in federal court. | Claims should be allowed to proceed in federal court despite state laches. | Lindberg/laches preclude relitigation of same claims. | Precluded; district court erred, injunction vacated, remanded to dismiss. |
Key Cases Cited
- Mack v. Utah State Dep’t of Commerce, Div. of Sec., 221 P.3d 194 (Utah 2009) (three-part test for claim preclusion)
- Allen v. McCurry, 449 U.S. 90 (U.S. 1981) (full faith and credit required preclusion of state judgments)
- Sierra Club v. Two Elk Generation Partners, Ltd. P’ship, 646 F.3d 1258 (10th Cir. 2011) (preclusion under 28 U.S.C. § 1738 follows state law for prior judgments)
- Fundamentalist Church of Jesus Christ of Latter-Day Saints v. Lindberg, 238 P.3d 1054 (Utah 2010) (laches dismissal of extraordinary writ is precedential for preclusion)
- Fundamentalist Church of Jesus Christ of Latter-Day Saints v. Home, 465 Fed. Appx. 768 (10th Cir. 2012) (certified-question context on merits-based denial for res judicata)