Anderson v. Vanguard Car Rental USA Inc.

Citations: 60 So. 3d 570; 2011 Fla. App. LEXIS 6659; 2011 WL 1775812Docket: No. 4D10-694

Court: District Court of Appeal of Florida; May 11, 2011; Florida; State Appellate Court

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Lennon Anderson appeals a final order dismissing his complaint against Vanguard Car Rental with prejudice, which was based on the doctrine of res judicata. The trial court determined that Anderson’s state law claims were identical to those in a previously dismissed federal complaint. Anderson had initially included state claims in his federal case but voluntarily withdrew them before the federal court dismissed the case with prejudice. This dismissal did not constitute a judgment on the merits regarding the state law claims.

Anderson's legal journey began when he filed a complaint against Vanguard in federal court on August 11, 2005. This federal complaint and a subsequent amended complaint were dismissed without prejudice for failure to state a claim. On August 10, 2007, he filed a second amended complaint with state law claims. Concurrently, on July 6, 2007, he filed a complaint in state court based on the same facts as the federal complaint, which included four counts matching those in the federal complaint. Vanguard responded with a motion to dismiss or stay the state proceedings, citing identical parties and issues.

Before the state court could act on Vanguard’s motion, Anderson voluntarily dismissed his federal state law claims. The state trial court subsequently stayed the case pending resolution of the federal matter. The federal court dismissed Anderson's claims with prejudice on February 29, 2008, and the dismissal was affirmed by the Eleventh Circuit and the U.S. Supreme Court denied certiorari, concluding federal appeals.

On November 24, 2009, Vanguard moved to lift the stay and dismiss Anderson’s state action, which the trial court granted based on res judicata. Anderson contends that because he voluntarily dismissed the state law claims from the federal suit, there was no final judgment on those claims, and thus, they should not be barred. The appellate court agrees, emphasizing that for res judicata to apply, there must be a final judgment on the merits regarding the same cause of action, which in this case is disputed. The court reviews the dismissal order de novo and reaffirms that the causes of action in the federal and state lawsuits are not identical. This analysis aligns with the principles of res judicata and federal claim preclusion.

Causes of action must arise under the same sovereign's laws to be considered identical, meaning a Florida state law claim and a federal claim are not identical under federal preclusion law, despite relating to the same transaction. A federal court's final judgment can bar state law claims if it adjudicates them on the merits. The doctrine of pendent jurisdiction allows plaintiffs to assert related state law claims alongside federal claims in federal court, which can lead to a bar on those claims in state court if the federal court issues a final judgment. In this case, Anderson's state law claims were dismissed voluntarily in federal court, and the court did not adjudicate the merits of those claims, only addressing federal law claims. Vanguard's argument that Anderson's state law claims are barred is rejected, referencing Bosdorf v. Sinnamon, which establishes that a voluntary dismissal with prejudice in federal court does not prevent re-filing in state court. Res judicata requires a claim to have been adjudicated on the merits, which did not occur here. Therefore, the trial court erred in dismissing Anderson’s state law claims based on res judicata, and the dismissal is reversed and remanded for further proceedings. Anderson's claims include Deliberate Indifference, Outrageous Conduct, Breach of Contract, Conspiracy, and Wrongful Termination, with some based on Florida law. The federal court's dismissals of earlier complaints were without prejudice, not judgments on the merits, further supporting that Anderson's state law claims can be adjudicated in state court. Any claims based solely on federal law, however, are procedurally barred.