Madsen v. JPMorgan Chase Bank, N.A.
296 P.3d 671
Utah2012Background
- Ms. Madsen pursued new litigation after Madsen IV, which addressed whether her prior accounting-type claims were preempted and remanded for entry of summary judgment in favor of the Bank.
- Madsen IV concluded federal preemption barred the state-law accounting claim for profits earned on pledged funds and noted possible private-contract variations, while finding no contractual obligation to pay interest in the absence of a contract or statute.
- Madsen IV instructed the district court to terminate the litigation on remand by entering summary judgment for the Bank, and the district court complied.
- Ms. Madsen appealed the district court’s affirmation of summary judgment; the current court reviews the preclusion issue rather than merits of new claims.
- The court notes that it previously denied reconsideration in Madsen IV and that Madsen IV’s reasoning is not preserved as a separate preclusion argument in this appeal.
- The court ultimately affirms the district court’s dismissal based on claim preclusion as to claims that could have been raised previously.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether res judicata bars the new complaint | Madsen contends Madsen IV did not resolve all pending claims; preemption discussion was dicta. | Madsen IV resolved merits and preemption, foreclosing new claims. | Yes, barred by res judicata. |
| Whether Madsen IV properly resolved all pending claims, not just some | Madsen argues Madsen IV didn’t resolve every possible claim. | Madsen IV resolved the merits and remanded for judgment; no open claims remained. | Madsen IV resolved all pending claims for purposes of preclusion. |
Key Cases Cited
- Snyder v. Murray City Corp., 73 P.3d 325 (2008 UT) (established elements of claim preclusion in Utah)
- Moss v. Parr Waddoups Brown Gee & Loveless, 285 P.3d 1157 (2012 UT) (clarified third element of claim preclusion)
- Gillmor v. Family Link, LLC, 284 P.3d 622 (2012 UT) (applies preclusion principles to related claims)
- Culbertson v. Board of County Commissioners of Salt Lake County, 44 P.3d 642 (2001 UT) (discussion of adjudication on the merits and preclusion)
- Brigham Young Univ. v. Tremco Consultants, Inc., 110 P.3d 678 (2005 UT) (references preclusion standards and adjudication on the merits)
- Allen v. Moyer, 259 P.3d 1049 (2011 UT) (notes on scope of claim preclusion)
- Madsen v. Washington Mutual Bank FSB (Madsen IV), 199 P.3d 898 (2008 UT 69) (preemption of state-law accounting claim; contract considerations; remand with judgment for Bank)