Youngin's Auto Body v. District of Columbia
2011 U.S. Dist. LEXIS 153282
| D.D.C. | 2011Background
- Youngin's Auto Body operated towing and auto body services in DC for ~20 years.
- Between Nov 2006 and Mar 2007, DCRA investigated Youngin's for tow regulations violations.
- On Apr 27, 2007, DCRA issued a Notice to Revoke Basic Business License for towing/storage.
- DCRA alleged five violations: owner’s rights print, prompt vehicle release, DPW control number, cash-only payments, and overcharging storage.
- July 2007: DC Superior Court granted TRO; Youngin's ceased operations on July 26, 2007.
- OAH granted revocation on Oct 4, 2007; motion for reconsideration stayed denied on Nov 16, 2007; Youngin's appealed on Nov 6, 2007.
- DC Court of Appeals affirmed OAH in Apr 15, 2009, but declined to address preemption because it wasn’t raised before the OAH.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether claim preclusion bars the current claims | Preemption claim not barred since not addressed earlier; §1983 claim not raised previously. | All current claims arise from same nucleus of facts and were or could have been litigated previously. | Barred; current claims arise from same nucleus of facts and should have been raised earlier. |
| Whether preemption claims were properly barred by res judicata | DC Court of Appeals declined to address preemption, so not barred. | Preemption arises from same factual core; could have been raised in prior proceedings. | Barred; preemption claim arose from same nucleus of facts and was not raised earlier. |
| Whether plaintiff had a full and fair opportunity to litigate claims in prior proceedings | Plaintiff did not have a full and fair opportunity to litigate §1983 and preemption claims. | OAH and DC Court of Appeals proceedings provided due process; plaintiff failed to raise claims. | Not available; full and fair opportunity existed; plaintiff failed to raise claims. |
Key Cases Cited
- Faulkner v. GEICO, 618 A.2d 181 (D.C. 1992) (causes of action defined by factual nucleus; same transaction)
- Patton v. Klein, 746 A.2d 866 (D.C. 1999) (three-part test for claim preclusion)
- Allen v. McCurry, 449 U.S. 90 (U.S. 1980) (final judgment on merits precludes relitigation)
- Kremer v. Chemical Constr. Corp., 456 U.S. 461 (U.S. 1982) (full faith and credit; apply state preclusion rules)
- Smith v. District of Columbia, 629 F. Supp. 2d 53 (D.D.C. 2009) (DC res judicata law; preclusion of related actions)
- Walker v. Seldman, 471 F. Supp. 2d 106 (D.D.C. 2007) (res judicata bars RICO and §1983 claims arising from same facts)