305 F. Supp. 3d 697
M.D. La.2018Background
- Slaughter was Southern University System President (appointed 2006). In 2007 he sued the Board and others and later settled; the settlement produced an employment contract through June 30, 2009.
- On March 27, 2009 the Board voted not to extend Slaughter’s contract; Slaughter then filed multiple suits (two state suits and this federal suit) alleging retaliation/whistleblower and related torts.
- Slaughter filed (1) an Open Meetings suit (dismissed voluntarily with prejudice) and (2) a state-law retaliation suit (dismissed with prejudice by trial court and affirmed by the Louisiana First Circuit on res judicata grounds).
- This federal suit asserts substantially the same operative facts as the state retaliation suit, adding individual board members as defendants and some post-vote allegations.
- Defendants moved for summary judgment in the federal case, arguing the state-court final judgment bars relitigation under Louisiana res judicata principles; the Court granted summary judgment and dismissed Slaughter’s federal claims with prejudice.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether the state-court final judgment bars the federal claims under res judicata | Slaughter contends the federal claims are not precluded (argues differences in parties/claims and that some allegations postdate the state suit) | Defendants argue the state final judgment is valid, final, involves the same parties/privity, and the federal claims arise from the same transaction/occurrence | Court held res judicata applies; federal claims dismissed with prejudice |
| Whether the individual board members are in the same-party/privity category | Slaughter argues individuals weren’t named in the state suit so they are not the same parties | Defendants argue officials sued in official capacity and individual board members are in privity with the Board (virtual representation/control/successor theories) | Court held privity exists between Board and individual members (official-capacity suits bind the government; virtual representation applies) |
| Whether allegations added in federal suit (post-vote releases/other retaliations) avoid preclusion | Slaughter contends some added facts are distinct and postdate the state judgment | Defendants argue the added allegations arise out of the same transaction (nonrenewal and fallout) and thus were or could have been asserted earlier | Court held the additional allegations arose from same transaction/occurrence and are precluded; even if not, some were insufficiently pleaded |
| Whether exceptional circumstances relieve res judicata bar | Slaughter argues an exception to res judicata should apply | Defendants maintain no exceptional circumstances exist; Slaughter voluntarily split claims and had opportunity to join them | Court held no exceptional circumstances; First Circuit already rejected that argument; res judicata stands |
Key Cases Cited
- Celotex Corp. v. Catrett, 477 U.S. 317 (summary judgment burdens and standards)
- Anderson v. Liberty Lobby, 477 U.S. 242 (evidence and inferences at summary judgment)
- Baker v. General Motors Corp., 522 U.S. 222 (full faith and credit and recognition of state judgments)
- Davis v. Dallas Area Rapid Transit, 383 F.3d 309 (res judicata / claim preclusion principles)
- Burguieres v. Pollingue, 843 So.2d 1049 (La. courts’ five-element res judicata test)
- Chevron USA Inc. v. State, 993 So.2d 187 (Louisiana focus on whether second action arises from same transaction or occurrence)