SCOTT v. WASHINGTON METROPOLITAN AREA TRANSIT AUTHORITY
1:24-cv-00487
D.D.C.Dec 2, 2024Background
- Kenneth Scott was involved in a multi-vehicle traffic accident with Kamilia Harden and a WMATA driver on November 3, 2021.
- Harden previously sued WMATA in Maryland state court for negligence arising from the same crash; WMATA removed that case to federal court, and Harden filed claims against both WMATA and Scott.
- The parties settled in federal court, with all claims and counterclaims dismissed with prejudice unless reopened in 30 days (Scott did not move to reopen).
- In 2024, Scott filed a new complaint in D.C. Superior Court based on the same incident; WMATA removed this action to federal court in D.C.
- Harden moved to dismiss Scott’s D.C. complaint, arguing it is barred by res judicata because the matter was already adjudicated—or could have been—in the prior federal case.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether res judicata bars Scott’s claim | No final judgment on merits; no need to bring counterclaim in prior case | Settlement order is a final judgment; Scott should have raised claim as compulsory counterclaim in prior federal action | Scott’s claim is barred by res judicata; dismissal with prejudice is final judgment; claim was compulsory and should have been raised |
| Whether federal or Maryland rules govern compulsory counterclaims | Maryland law applies, so Scott was not required to bring counterclaim | Federal rules apply after removal; claim arising from same events must be raised | Federal rules govern; Scott’s counterclaim was compulsory and should have been asserted |
| Effect of absence of factual determination (trial) on claim preclusion | No merits determination so preclusion is inapplicable | Dismissal with prejudice (including by settlement) is sufficient for claim preclusion | Factual finding is not required; dismissal with prejudice is a final judgment for claim preclusion |
| Difference in claims based on party status (plaintiff vs. defendant) | Elements of damages and causation differ depending on party status | Underlying facts are same; arises from same incident so claim preclusion applies | Cause of action is the same because it arises from the same nucleus of facts |
Key Cases Cited
- Arizona v. California, 530 U.S. 392 (final judgment bars relitigation of claims, factual determination not required for claim preclusion)
- Taylor v. Sturgell, 553 U.S. 880 (federal common law governs preclusive effect of federal-court judgments)
- Bell Atl. Corp. v. Twombly, 550 U.S. 544 (plausibility standard for 12(b)(6) motions)
- Ashcroft v. Iqbal, 556 U.S. 662 (plausibility pleading standard clarified)
- Migra v. Warren City School Dist. Bd. of Educ., 465 U.S. 75 (claim preclusion applies to matters that could have been raised in earlier suit)
- Hanna v. Plumer, 380 U.S. 460 (federal procedural rules apply in federal court despite differing state rules)