Keith Goodwin v. Summit Cnty., Ohio
703 F. App'x 379
| 6th Cir. | 2017Background
- Summit County sued Keith Goodwin and his HVAC company in Ohio state court (Oct 2012) for alleged ordinance violations; Goodwin answered and amended answers raising affirmative defenses but no counterclaims.
- While state case was pending, Goodwin filed a § 1983 suit in federal court (Jan 2014) against the County, County departments, and several County officials seeking injunctive/declaratory relief and damages for due process, equal protection, and takings violations.
- District court dismissed the departments and officials (concluding they were sued only in official capacity) and stayed the federal case pending the state proceedings; state court later entered judgment for Goodwin after a bench trial.
- Goodwin moved to reopen the federal case and sought leave to file a proposed amended complaint (PAC) that repleaded the same claims and newly named the previously-dismissed officials in both official and individual capacities plus a malicious-prosecution claim.
- The County moved to dismiss on res judicata and statute-of-limitations grounds; the district court denied leave to amend, granted dismissal based primarily on claim preclusion; Goodwin appealed.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether the original complaint put officials on notice of individual-capacity suits | Goodwin said the complaints and later references put officials on notice they might be sued individually | County argued caption and pleadings explicitly limited officials to official-capacity, so no notice of individual liability | Court: Officials were sued only in official capacity; dismissal of individual claims was proper |
| Whether the PAC’s individual-capacity claims relate back to original complaint (Fed. R. Civ. P. 15) | Goodwin argued relation-back because claims arise from same conduct and officials had notice during Rule 4(m) period | County argued original pleadings and conduct gave no notice; claims were time-barred and did not relate back | Court: Relation-back fails; PAC individual-capacity claims untimely and do not relate back |
| Whether federal constitutional claims are precluded by Ohio res judicata (claim preclusion) | Goodwin contended some evidence was discovered later and constitutional claims were not compulsory in state action | County argued the state- and federal-claims arise from same transaction/occurrence and were or could have been litigated in state court | Court: Res judicata applies; constitutional claims barred because they were compulsory or could have been raised in state action |
| Whether district court abused discretion by denying leave to amend | Goodwin argued amendment should be allowed to add individual-capacity officials and malicious prosecution claim | County argued amendment futile due to res judicata and statute of limitations | Court: Denial proper because amendment would be futile (claims barred) |
Key Cases Cited
- Moore v. City of Harriman, 272 F.3d 769 (6th Cir.) (capacity pleading and reliance on course of proceedings for notice)
- Doe v. Claiborne Cty., 103 F.3d 495 (6th Cir.) (official- vs. individual-capacity pleading principles)
- Krupski v. Costa Crociere S. p. A., 560 U.S. 538 (2010) (relation-back inquiry focuses on prospective defendant’s notice during service period)
- Grava v. Parkman Twp., 73 Ohio St.3d 379 (Ohio 1995) (Ohio’s adoption and limits of Restatement (Second) of Judgments for res judicata)
- Hapgood v. City of Warren, 127 F.3d 490 (6th Cir.) (choice-of-law: state law governs preclusive effect of state-judgment)
- Migra v. Warren City Sch. Dist. Bd. of Educ., 465 U.S. 75 (1984) (preclusive effect of state-court judgments in federal courts)
- Bauman v. Bank of America, N.A., 808 F.3d 1097 (6th Cir.) (analysis of whether a claim is compulsory as a counterclaim)