Mead v. Lindlaw
2012 U.S. Dist. LEXIS 33225
D.D.C.2012Background
- Mead, proceeding pro se, sued multiple defendants over two Washington, D.C. loans, foreclosure, and subsequent sale of his property.
- Defendants moved to dismiss under Rule 12(b)(6) for failure to state a claim.
- Court held Count Two barred by collateral estoppel, and Counts Six and Eight barred by res judicata; remaining state-law claims dismissed for lack of federal jurisdiction.
- Mead had prior federal litigation (2008–2009) where Judge Roberts dismissed the RFPA claim for failure to state a claim and declined supplemental jurisdiction over remaining state-law claims.
- Mead also pursued a D.C. Superior Court action; Judge Iscoe later granted summary judgment for Defendants, declaring the foreclosure sale valid.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Is Count Two barred by collateral estoppel? | Mead argues collateral estoppel does not apply because the prior action raised different issues/defendants. | Defendants contend Count Two sought essentially the same RFPA claim already dismissed in the prior federal action. | Count Two barred by collateral estoppel. |
| Are Counts Six and Eight barred by res judicata? | Mead argues these claims involve different theories and should not be precluded. | Defendants assert Counts Six and Eight arise from the same transaction and could have been raised in the Superior Court action. | Counts Six and Eight barred by res judicata. |
| Should the court exercise supplemental jurisdiction over remaining state-law claims? | Plaintiff seeks continuation of federal adjudication over all claims. | Defendants argue discretion weighs against exercising supplemental jurisdiction given dismissal of federal claims and local nature of remaining claims. | Court declined to exercise supplemental jurisdiction over remaining state-law claims. |
| Are Counts One, Three, Four, and Five barred by res judicata or related defenses? | Mead contends these claims are distinct state-law issues. | Defs. argue these claims arise from the same nucleus of facts and could have been raised in the Superior Court action. | Counts One, Three, Four, and Five not barred by res judicata. |
Key Cases Cited
- Parklane Hosiery Co. v. Shore, 439 U.S. 315 (U.S. 1979) (mutuality not required for defensive collateral estoppel)
- Blonder-Tongue Laboratories, Inc. v. University of Illinois Foundation, 402 U.S. 313 (U.S. 1971) (preclusion principles and collateral estoppel scope)
- Novak v. World Bank, 703 F.2d 1305 (D.C. Cir. 1983) (defensive collateral estoppel principles)
- United Mine Workers of Am. v. Gibbs, 383 U.S. 715 (U.S. 1966) (supplemental jurisdiction and related doctrines)
- Leslie v. Laprade, 726 A.2d 1228 (D.C. 1999) (claim preclusion scope applies to related claims)
- Carr v. Rose, 701 A.2d 1065 (D.C. 1997) (whether later claims may be barred as same cause of action)
- Faulkner v. Gov’t Emps. Ins. Co. (GEICO), 618 A.2d 181 (D.C. 1992) (defining preclusion standards in D.C. cases)
- Amos v. Shelton, 497 A.2d 1082 (D.C. 1985) (nucleus of operative facts for res judicata)