775 F.3d 1057
8th Cir.2015Background
- Magee, a tenured Hamline University School of Law professor, was placed on leave and later terminated following state tax felony proceedings and a 2011 conviction on misdemeanor tax-return counts.
- Magee filed Magee I (42 U.S.C. § 1983) in April 2011 against Hamline's Dean Lewis, the Trustees, and a police officer, alleging concerted conduct and claims for intentional interference/breach related to her termination.
- Dean Lewis initiated Magee's discharge process in May 2011, and Magee was officially terminated on July 21, 2011 after a faculty committee recommended discharge.
- Magee II, filed in May 2013, asserted a § 1981 claim against Hamline and Lewis alleging racial discrimination affecting contractual relationships, which the district court dismissed as barred by res judicata in 2014.
- The appellate court reviewed de novo and held that Magee II's § 1981 claim arose from the same nucleus of operative facts as Magee I’s § 1983 claim and was therefore precluded by res judicata.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether Magee II is barred by claim preclusion | Magee contends § 1981 claim was not raised in Magee I. | Defendants contend Magee II arises from the same facts as Magee I and is barred. | Yes; res judicata bars Magee II. |
| Whether the two suits involve the same nucleus of operative facts | Magee asserts distinct § 1981 claim facts post-termination were new. | District court found the conduct and termination events overlap the prior § 1983 suit. | Yes; same nucleus of operative facts. |
Key Cases Cited
- Domino’s Pizza, Inc. v. McDonald, 546 U.S. 470 (U.S. 2006) (illustrates scope of § 1981 in contractual relationships and discrimination)
- Costner v. URS Consultants, Inc., 153 F.3d 667 (8th Cir. 1998) (same nucleus of operative facts test for claims preclusion)
- Knutson v. City of Fargo, 600 F.3d 992 (8th Cir. 2010) (elements of claim preclusion and relitigation prohibition)
- Yankton Sioux Tribe v. U.S. Dep’t of Health & Human Servs., 533 F.3d 634 (8th Cir. 2008) (definition of same claims or causes of action under res judicata)
- N.A.A.C.P. v. Metro. Council, 125 F.3d 1171 (8th Cir. 1997) (review of res judicata at pleading stage)