Harris v. Standard Guaranty Insurance Company
2:24-cv-00153
N.D. Ala.Mar 11, 2025Background
- Plaintiff Roderick Harris, acting pro se as administrator of the Estate of Martha C. Harris, brought suit against Standard Guaranty Insurance Company, Crawford & Company, and Wells Fargo Bank alleging breach of contract, negligence, bad faith, conversion, conspiracy, fraud, and corruption related to insurance proceeds from a 2018 house fire.
- This is the third federal lawsuit brought by Harris over the same nucleus of facts, following two prior actions (Harris I and Harris II) regarding the same property and insurance proceeds.
- In the first case (Harris I), the parties entered into a mediated settlement agreement, confirmed on record in open court, after which the action was dismissed with prejudice.
- Harris subsequently attempted to repudiate the settlement and filed a second suit (Harris II), which was dismissed by summary judgment on the grounds that the settlement was valid, binding, and that all claims had been released.
- In this third suit, Harris's complaint was found to contain no factual allegations, failing to segregate legal claims or provide notice to defendants (Type III shotgun pleading).
- The court considered motions to dismiss (Crawford) and for summary judgment (Wells Fargo), both raising claim preclusion (res judicata) and pleading deficiencies.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Is the complaint a shotgun pleading? | Harris did not address, but broadly alleged multiple wrongs in a single statement. | Complaint fails to separate causes of action or include supporting facts. | Yes, the complaint is a Type III shotgun pleading and subject to dismissal. |
| Does the complaint state a plausible claim? | Claims asserted in general terms without factual support. | Complaint lacks factual content required by Fed. R. Civ. P. 8(a) and 12(b)(6). | No, it fails to state a claim and is dismissed. |
| Are Plaintiff's claims barred by res judicata? | Harris contends cases are "unresolved" and raises procedural objections. | Prior judgments on merits; parties and claims identical; same nucleus of facts. | Yes, all claims against moving defendants are barred by res judicata. |
| Can Plaintiff amend to cure deficiencies? | Does not seek to amend. | Any amendment would be futile due to res judicata bar. | Leave to amend denied as futile. |
Key Cases Cited
- Ashcroft v. Iqbal, 556 U.S. 662 (2009) (standard for pleading facial plausibility under Rule 8(a))
- Bell Atlantic Corp. v. Twombly, 550 U.S. 544 (2007) (pleading must include more than labels and conclusions)
- Anderson v. Liberty Lobby, Inc., 477 U.S. 242 (1986) (standard for summary judgment—genuine issue for trial)
- Celotex Corp. v. Catrett, 477 U.S. 317 (1986) (summary judgment procedure and burden-shifting)
- Weiland v. Palm Beach Cnty. Sheriff's Off., 792 F.3d 1313 (11th Cir. 2015) (shotgun pleading doctrine)
- Ragsdale v. Rubbermaid, Inc., 193 F.3d 1235 (11th Cir. 1999) (claim preclusion/res judicata elements)