Linda Reed v. Columbia St. Mary's Hospital
2015 U.S. App. LEXIS 5085
7th Cir.2015Background
- Reed, a disabled inpatient, sues Columbia St. Mary’s Hospital alleging ADA and Rehabilitation Act discrimination during March 2012 stay.
- Her first case was dismissed by Judge Stadtmueller for failure to state a claim under Rule 8(a)(2), without prejudice, inviting amendment.
- The district court later dismissed that case as lacking federal jurisdiction and without prejudice, based on purported failure to state federal claims.
- Reed then filed a second case in the same court with similar facts; Judge Randa dismissed at screening, citing claim preclusion and lack of ADA/RA remedies.
- The Seventh Circuit held Stadtmueller’s dismissal did not actually resolve jurisdiction and Reed may pursue ADA/RA claims; 1983 claims were properly dismissed.
- Remand to proceed with ADA/RA claims and potential relief, including compensatory damages under the Rehabilitation Act, while keeping 1983 claims failed.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether first dismissal precludes the second suit | Reed argues Stadtmueller’s lack-of-jurisdiction dismissal was not actually a jurisdictional ruling and thus not preclusive. | Randa treated the first dismissal as precluding the second based on subject-matter jurisdiction. | First dismissal not preclusive; jurisdiction issue not actually litigated; remand permitted. |
| Whether Reed states viable ADA and Rehabilitation Act claims | Reed states discrimination/retaliation claims actionable under ADA and RA. | District court believed no remedies or cognizable claims existed under ADA/RA. | ADA and RA claims viable at pleading stage; 1983 claims fail. |
| Whether Rehabilitation Act retaliation claims extend to non-employment context | RA retaliation claims are available outside employment contexts. | RA retaliation applicability limited or not clearly established. | RA retaliation claims outside employment are viable. |
| What remedies exist under the Rehabilitation Act for these claims | Compensatory damages may be available for non-employment discrimination/retaliation. | Remedies under RA limited or not clearly permitting damages for these facts. | Compensatory damages may be available for intentional discrimination under RA; scope to be determined later. |
| Whether §1983 claims fail due to lack of state action | RA/ADA claims support relief; §1983 should not be limited by state-action requirement. | Hospital is private; no color of state law. | §1983 dismissal upheld; ADA/RA claims proceed. |
Key Cases Cited
- Hill v. Potter, 352 F.3d 1142 (7th Cir. 2003) (issue preclusion requires an actually litigated jurisdiction ruling)
- Okoro v. Bohman, 164 F.3d 1059 (7th Cir. 1999) (actual litigation of jurisdiction necessary for preclusion)
- Matrix IV, Inc. v. American Nat’l Bank & Trust Co., 649 F.3d 539 (7th Cir. 2011) (need for actual litigation to support preclusion analysis)
- La Preferida, Inc. v. Cerveceria Modelo, S.A. de C.V., 914 F.2d 900 (7th Cir. 1990) (look beyond judgment to determine whether issues were actually litigated)
- Gogos v. AMS Mch. Sys., Inc., 737 F.3d 1170 (7th Cir. 2013) (mischaracterization of jurisdictional ruling can be ignored when not actually litigated)
- Paganis v. Blonstein, 3 F.3d 1067 (7th Cir. 1993) (merits-like ruling may be deemed non-final for preclusion concerns)
- McCoy v. Iberdrola Renewables, Inc., 760 F.3d 674 (7th Cir. 2014) (failure to state a claim does not automatically destroy jurisdiction unless wholly frivolous)
- Bovee v. Broom, 732 F.3d 743 (7th Cir. 2013) (clarifies standards for jurisdictional dismissal versus merits dismissal)
- Bell v. Hood, 327 U.S. 678 (1946) (limits on jurisdictional dismissal for non-frivolous claims)