Jiles v. United Parcel Service, Inc.
413 F. App'x 173
11th Cir.2011Background
- Jiles appealed the district court's dismissal of his FMLA interference and retaliation claims against UPS.
- District court granted judgment on the pleadings, finding FMLA claims barred by res judicata due to Jiles I (race discrimination/retaliatory termination).
- Jiles contends the FMLA claims do not arise from the same nucleus of operative fact as the prior suit and could not have been raised earlier.
- The district court held the FMLA claims relate to the same termination events as in Jiles I.
- Jiles argues the delayed discovery rule should avert res judicata, since he learned of the FMLA miscalculation in discovery for the earlier case, but the court rejected this.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether FMLA claims barred by res judicata. | Jiles argues not arising from same nucleus of facts; could not have been raised earlier. | Claims arise from same termination events; should have been raised in Jiles I. | Barred; res judicata applies. |
| Whether delayed discovery prevents preclusion. | Delayed discovery should toll accrual, allowing FMLA claims to proceed. | Delayed discovery does not apply; failure to investigate earlier is on Jiles. | No; delayed discovery does not save the claims. |
Key Cases Cited
- O'Connor v. PCA Family Health Plan, Inc., 200 F.3d 1349 (11th Cir. 2000) (same-termination-based res judicata analysis)
- Mpoyo v. Litton Electro-Optical Sys., 430 F.3d 985 (9th Cir. 2005) (claims from termination relate to same facts)
- Trustmark Ins. Co. v. ESLU, Inc., 299 F.3d 1265 (11th Cir. 2002) (delayed discovery rule; accrual timing)
- In re Delta Resources, Inc., 54 F.3d 722 (11th Cir. 1995) (judicial notice of other court orders)
- Twombly v. Bell Atlantic Corp., 550 U.S. 544 (U.S. Supreme Court 2007) (plausibility standard for pleading)