746 F. Supp. 2d 163
D.D.C.2010Background
- Johnson seeks discharge of federally guaranteed loans against Secretary and ACS.
- He previously litigated similar discharge claims under APA and HEA, and that suit ended in judgment for defendants.
- UMUC paralegal studies program and Johnson's criminal history were central to the prior decision regarding whether the program specifically trained for employment in law enforcement or as a paralegal.
- Johnson contends false certification and due-process violations; district court and circuit court upheld the denial of discharge.
- The current Second Amended Complaint repeats the prior theories; the court sua sponte raises res judicata and collateral estoppel concerns and sua sponte dismisses accordingly.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether claims are precluded by res judicata/collateral estoppel | Johnson asserts new filings but raises same discharge issues | Duncan/ACS show prior final adjudication on related claims | Yes; claims barred by res judicata and collateral estoppel |
| Whether mandamus relief should be granted | Johnson seeks to compel action by Secretary | No clear right or duty; inadequate grounds | No; mandamus denied |
| Whether Third Amended Complaint is a futile amendment | Proposed facts would alter result | Claims reiterate already-barred issues | Denied; amendment futile |
| Whether relief under Rule 60(b) or remand were proper avenues | Seeking relief from judgment or remand to consider new facts | Courts previously denied; no basis to reconsider | Denied; no basis to revisit judgments |
Key Cases Cited
- Parklane Hosiery Co. v. Shore, 439 U.S. 322 (1979) (preclusion and full and fair opportunity to litigate underpin res judicata)
- Montana v. United States, 440 U.S. 147 (1979) (final judgment on merits; efficiency and consistency goals)
- U.S. Indus., Inc. v. Blake Constr. Co., 765 F.2d 195 (D.C.Cir. 1985) (Restatement approach to transaction-based causation for res judicata)
- Allen v. McCurry, 449 U.S. 90 (1981) (collateral estoppel; actually litigated and necessarily decided issues)
- Yamaha Corp. v. United States, 961 F.2d 245 (D.C.Cir. 1992) (issue preclusion principles apply across subsequent actions)
- Am. Forest Res. Council v. Shea, 172 F.Supp.2d 24 (D.D.C. 2001) (identifies four-element test for res judicata in this circuit)
- In re Medicare Reim. Litig., 414 F.3d 7 (D.C.Cir. 2005) (mandamus standards; heightened showing required)
- 13th Reg'l Corp. v. U.S. Dep't of Interior, 654 F.2d 758 (D.C.Cir. 1980) (mandamus availability and equitable considerations)