Williams v. Mastronardi Produce-USA, Inc.
2:24-cv-13195
| E.D. Mich. | Jul 31, 2025Background
- Diamond Williams previously brought an employment discrimination and retaliation lawsuit against Mastronardi Produce Ltd. (Mastronardi Canada), alleging mistreatment while employed at a Michigan warehouse.
- Records established that Williams was actually employed by Mastronardi Produce-USA, Inc. (Mastronardi-USA), a subsidiary of Mastronardi Canada.
- Williams was given multiple opportunities in the original suit to amend her complaint to name the proper defendant after being presented with evidence of her actual employer, but she failed to do so.
- The court in the first case granted summary judgment in favor of Mastronardi Canada, finding that it was not Williams' employer; her complaint was dismissed with prejudice and she did not appeal.
- Williams immediately filed a new, nearly identical lawsuit—this time against Mastronardi-USA.
- Mastronardi-USA moved to dismiss this new action based on res judicata (claim preclusion), and the court here addresses whether this doctrine bars Williams' claims.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Was the prior judgment a final decision on the merits? | Judgment was procedural, about party identity | Summary judgment is a merits decision | Summary judgment on employer identity is merits adjudication |
| Are Mastronardi Canada and Mastronardi-USA in privity? | Mere parent-subsidiary link insufficient | Close, significant relationship + joint employer claim | Close relationship and facts satisfy privity requirement |
| Could claims against Mastronardi-USA have been litigated in prior case? | Mastronardi-USA not a named party, so claims couldn't have been addressed | Claims could and should have been raised in first suit | Claims could have been litigated; Williams controlled both suits |
| Is there identity of causes of action between the two lawsuits? | New employer named, hostile environment claim added | Operative facts and law virtually identical | Both arise from same events; cause of action identity met |
Key Cases Cited
- Allen v. McCurry, 449 U.S. 90 (1980) (explaining the purposes behind res judicata)
- Ashcroft v. Iqbal, 556 U.S. 662 (2009) (setting out Rule 12(b)(6) pleading standard)
- Bell Atl. Corp. v. Twombly, 550 U.S. 544 (2007) (plausibility standard for complaints)
- Sanders Confectionery Prod., Inc. v. Heller Fin., Inc., 973 F.2d 474 (6th Cir. 1992) (identity of causes of action in preclusion)
- Bittinger v. Tecumseh Prods. Co., 123 F.3d 877 (6th Cir. 1997) (elements for claim preclusion/ res judicata)
- Stemler v. Florence, 350 F.3d 578 (6th Cir. 2003) (summary judgment is an adjudication on merits)
- Taylor v. Sturgell, 553 U.S. 880 (2008) (preclusive effect of federal court judgments; privity)
- Tohono O’Odham Nation, 563 U.S. 307 (2011) (claims arise from same transaction for preclusion)