St. Jude Medical S.C., Inc. v. Annette Cormier
745 F.3d 325
8th Cir.2014Background
- St. Jude sued Medtronic in Florida state court for unfair competition and tortious interference with its relationship with Joe Cormier; they arbitrated those claims and St. Jude later pursued related claims against Annette in federal court.
- Annet te Cormier left St. Jude for Medtronic in 2009; after arbitration found Medtronic liable, St. Jude sued Annette in federal court for unjust enrichment, contract, tortious interference, misappropriation, civil conspiracy, and fiduciary breach.
- Annette moved for judgment on the pleadings based on res judicata; the district court granted judgment to Annette.
- The arbitration panel found Medtronic tortiously interfered with St. Jude’s relationship with Joe and awarded lost profits.
- Florida law governs res judicata if Florida rendered the first judgment; the court engages in a four-element Florida test: identity of parties, identity of capacity, identity of the cause of action, and identity of the thing sued for.
- The court holds some counts arising from Annette’s acts as a St. Jude employee are not barred by res judicata, while Counts 2 and 4 are affirmed as barred.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| What law governs res judicata analysis? | Annette argues Minnesota law; | Florida law should apply as forum that rendered arbitration judgment; | Florida law applies |
| Does privity/identity of parties bar St. Jude's claims based on Annette's acts as a St. Jude employee? | Annette contends privity with Medtronic; | No privity for pre-Medtronic acts; | Counts arising from Annette's St. Jude acts not barred; privity fails for those acts |
| Is there identity of capacity for res judicata regarding Annette’s pre-Medtronic acts? | Privity shows identity of capacity; | Capacity differs for pre- and post- Medtronic acts; | No identity of capacity for pre-Medtronic acts |
| Is there identity of the cause of action between the Florida arbitration and federal case? | Underlying facts/evidence are same; | Different procedural posture; | Yes, identity of cause of action established for those counts |
| Is there identity of the thing sued for? | Damages sought in both actions; | Not contested below; | Counts 1, 3, 5, and 6 not barred on this basis |
Key Cases Cited
- St. Paul Fire & Marine Ins. Co. v. Compaq Computer Corp., 539 F.3d 809 (8th Cir. 2008) (controls choice of law for res judicata)
- Austin v. Super Valu Stores, Inc., 31 F.3d 615 (8th Cir. 1994) (forum-state law governs res judicata)
- Dadeland Depot, Inc. v. St. Paul Fire & Marine Ins. Co., 945 So.2d 1216 (Fla. 2006) (Florida’s four-factor test for res judicata)
- Tyson v. Viacom, Inc., 890 So.2d 1205 (Fla. Dist. Ct. App. 2005) (identity of the cause of action)
- Hinton v. Iowa Nat’l Mut. Ins. Co., 317 So.2d 832 (Fla. Dist. Ct. App. 1975) (privity and master-servant context for res judicata)
- Phillips v. Hall, 297 So.2d 136 (Fla. Dist. Ct. App. 1974) (privity considerations in res judicata)
- ICC Chem. Corp. v. Freeman, 640 So.2d 92 (Fla. Dist. Ct. App. 1994) (limitations on privity interpretation)
- Atlantic Cylinder Corp. v. Hetner, 438 So.2d 922 (Fla. Dist. Ct. App. 1983) (company liability and privity context)
- Hinton v. Iowa Nat’l Mut. Ins. Co., 317 So.2d 832 (Fla. Dist. Ct. App. 1975) ()