Sullivan's Administrative Managers II, LLC v. Guarantee Insurance Company
713 F. App'x 845
| 11th Cir. | 2017Background
- SAM II sued Guarantee in Georgia state court alleging misreporting/overbilling and claims including negligent misrepresentation, breach of contract, fraud, conversion, and RICO-related allegations tied to four workers’ compensation policies.
- Defendants removed to federal court based on diversity jurisdiction; Guarantee counterclaimed for breach of contract alleging unpaid deductible premiums under the same four policies.
- Guarantee had earlier sued SAM I in Florida state court over the same premiums; the Florida court granted Guarantee summary judgment and entered a final judgment for $1,376,537.35, later affirmed on appeal.
- Guarantee moved in federal court for summary judgment on res judicata and collateral estoppel grounds based on the Florida judgment; the district court stayed the motion pending appeal in Florida, then granted summary judgment for Guarantee after the Florida judgment was affirmed.
- SAM II challenged application of Florida preclusion principles (arguing Georgia law should apply), but conceded Florida courts correctly applied Florida law; the Eleventh Circuit affirmed the district court’s grant of summary judgment for Guarantee.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether Florida res judicata bars SAM II’s federal action | SAM II argued Florida preclusion shouldn’t apply because Georgia law governs and the causes of action differ | Guarantee argued Florida judgment against SAM I precludes SAM II (identity/privity); same facts/evidence underlie both suits | Affirmed: Florida res judicata applies; claims were or could have been raised in Florida action, so barred |
| Whether collateral estoppel prevents relitigation of issues decided in Florida | SAM II contended issues (choice of law, delivery, exhaustion) weren’t identical or binding under Georgia law | Guarantee argued identical issues were fully litigated in Florida and decided on the merits | Affirmed: Collateral estoppel under Florida law applies; issues were fully litigated and decided |
| Whether parties/identities prevent preclusion (SAM I v. SAM II) | SAM II disputed non-identity of parties (litigated as SAM I in Florida) | Guarantee asserted SAM II is identical to or in privity with SAM I; SAM II litigated the Florida proceedings | Affirmed: Parties/privity sufficient for preclusion; SAM II conceded it litigated Florida action |
| Choice-of-law challenge to preclusion effect | SAM II argued district court erred applying Florida law rather than Georgia law | Guarantee and courts noted Full Faith and Credit/28 U.S.C. §1738 require federal courts to give Florida judgments the preclusive effect Florida law provides | Affirmed: Federal court must apply Florida preclusion law; SAM II’s concession that Florida law was correctly applied forecloses reversal |
Key Cases Cited
- Goodman v. Kimbrough, 718 F.3d 1325 (11th Cir.) (standard of review for summary judgment)
- In re Optical Techs., Inc., 246 F.3d 1332 (11th Cir.) (summary judgment genuine-issue standard)
- Kizzire v. Baptist Health Sys., Inc., 441 F.3d 1306 (11th Cir.) (apply preclusion principles of state whose judgment is a bar)
- Lozman v. City of Riviera Beach, Fla., 713 F.3d 1066 (11th Cir.) (elements of claim preclusion under Florida law)
- Davila v. Delta Air Lines, Inc., 326 F.3d 1183 (11th Cir.) (res judicata bars claims that could have been raised previously)
- Quinn v. Monroe Cty., 330 F.3d 1320 (11th Cir.) (elements of collateral estoppel under Florida law)
- Vasquez v. YII Shipping Co., 692 F.3d 1192 (11th Cir.) (issue preclusion prevents relitigation of decided issues)
- Jones v. Gann, 703 F.2d 513 (11th Cir.) (res judicata defense can be resolved on summary judgment)