Meanith Huon v. Johnson & Bell, Limited
2014 U.S. App. LEXIS 18774
7th Cir.2014Background
- Huon, a former associate at Johnson & Bell, sued the firm and several attorneys in state court for defamation and intentional infliction of emotional distress.
- The state court dismissed Huon’s claims in July 2009 for failure to state a claim; Huon appealed and framed the alleged defamation as pretext for racial/national-origin discrimination.
- Huon then filed a federal complaint in late 2009 asserting Title VII and §1981 discrimination and a state-law claim, spanning December 2003–January 2008.
- The district court stayed the federal case under Colorado River; on remand, the court applied Illinois claim preclusion and granted judgment for defendants.
- The district court held that Huon’s federal suit was barred by claim preclusion due to a final judgment in state court and an identity of causes of action and parties.
- On appeal, Huon argued lack of identity of claims, lack of privity, and procedural impediments to litigating in state court; the Seventh Circuit affirmed the district court’s application of claim preclusion.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether there is identity of claims under Illinois law for claim preclusion | Huon argues the federal and state suits involve different decisions over time. | Johnson & Bell contends the suits arose from a single series of connected transactions. | Yes; there is identity of claims under the transactional/pra gmatic test. |
| Whether there is identity of parties or their privies | Huon claims lack of privity between some federal and state defendants. | Defendants assert privity through shared interests and conduct; firm president aligns with the firm. | Yes; there is identity of parties/privity under Illinois law. |
| Whether Huon was denied a full and fair opportunity to litigate in state court | Huon alleges defendants prevented federal claims from being raised via state court tactics. | Huon never alleged discrimination in his state complaint and did not amend to add such claims. | No; preclusion applies because failure to litigate in state court cannot be blamed on defendants. |
| Whether Blount v. Stroud affected availability of filing federal claims in state court | Huon relied on Blount to bar federal claims from state court. | Blount was not necessary to preclude federal claims, as other routes existed. | No; Blount’s rule did not bar Huon from presenting federal claims in state court. |
| Whether district court properly treated the Rule 12(c) motion as appropriate for claim-preclusion analysis | Huon argues the court considered matters outside the pleadings. | Court limited itself to public-record materials and pleadings. | Yes; proper for Rule 12(c) in this context. |
Key Cases Cited
- River Park, Inc. v. City of Highland Park, 703 N.E.2d 883 (Ill. 1998) (defines transaction/series of connected transactions for claim preclusion)
- Doe v. Gleicher, 911 N.E.2d 532 (Ill. App. Ct. 2009) (transactional approach to claim preclusion)
- Lane v. Kalcheim, 915 N.E.2d 93 (Ill. App. Ct. 2009) (time-related considerations in same transaction analysis)
- Hayes v. City of Chicago, 670 F.3d 810 (7th Cir. 2012) (convenient trial unit; pragmatic transactional test)
- Cload ex rel. Cload v. West, 767 N.E.2d 486 (Ill. App. Ct. 2002) (series of connected transactions under Illinois law)
- 1 4901 Corp. v. Town of Cicero, 220 F.3d 522 (7th Cir. 2000) (transactional approach to claim preclusion)
- Dookeran v. Cnty. of Cook, 719 F.3d 570 (7th Cir. 2013) (preclusion despite Blount timing; full and fair opportunity)
- Blount v. Stroud, 904 N.E.2d 1 (Ill. 2009) (examined in preclusion context (timing))