James Eric Crain v. CRST Van Expedited, Inc.
2011 Tenn. App. LEXIS 240
| Tenn. Ct. App. | 2011Background
- Crain, Knoxville resident, signed a pre-employment training agreement and a driver employment contract with CRST Van Expedited, Inc.
- Crain was trained and subsequently terminated; CRST sought payment under the contract.
- Crain sued in Knox County Chancery Court seeking injunctive relief and CRST asserted damages in counterclaim.
- CRST also sued Crain in Iowa on the same facts; Iowa judgment awarded CRST $4,818.39 plus fees and costs in 2009.
- Crain did not appeal the Iowa judgment; CRST moved to domesticate the Iowa judgment and for summary judgment in Tennessee.
- Trial court granted summary judgment on res judicata and, alternatively, under the Uniform Enforcement of Foreign Judgments Act; Crain appealed.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether res judicata bars Crain's Tennessee claims | Crain argues not barred by prior litigation | CRST contends Iowa judgment precludes anew claims | Res judicata applies; Iowa judgment bars Tennessee claims |
| Whether the Iowa judgment should be domesticated under the Uniform Enforcement of Foreign Judgments Act | Crain challenges enforcement as contrary to public policy | CRST argues proper domestication and enforcement of foreign judgment | CRST entitled to enforcement of Iowa judgment under the Act |
Key Cases Cited
- Lien v. Couch, 993 S.W.2d 53 (Tenn. Ct. App. 1998) (four elements of res judicata; final on merits; same parties; same cause of action)
- Bio-Technology Gen. Corp. v. Genentech, Inc., 80 F.3d 1553 (Fed. Cir. 1996) (claim preclusion; require raising all grounds in single action)
- Hannan v. Alltel Publ’g Co., 270 S.W.3d 1 (Tenn. 2008) (summary judgment standards; evidentiary burden shifting)
- White v. White, 876 S.W.2d 837 (Tenn. 1994) (reexamination after prior judgment; changed facts may affect claims)
- Biogen Distribs., Inc. v. Tanner, 842 S.W.2d 253 (Tenn. Ct. App. 1992) (domestication of foreign judgments; summary judgment permissible)
- Dement v. Kitts, 777 S.W.2d 33 (Tenn. Ct. App. 1989) (public policy limits on full faith and credit; stern burden to defeat enforcement)
- Coastcom, Inc. v. Cruzen, 981 S.W.2d 179 (Tenn. Ct. App. 1998) (public policy and enforcement of foreign judgments)