Eleventh Circuit Rejects Employer’s Rooker-Feldman, Claim Preclusion and Res Judicata Arguments

Franklin Vazquez, a Jones Act seaman, suffered injuries when a gas-powered tool exploded in his hands while working.  He filed suit against his employer in Florida state court but his case was eventually dismissed under Florida’s doctrine of forum non conveniens.  Vasquez later brought identical claims in federal district court.  The district court concluded that under principles of res judicata and collateral estoppel, Vasquez was barred from litigating the facts relevant to his federal maritime claims.  The district court ultimately dismissed the case based on federal forum non conveniens and the Rooker-Feldman doctrine.

Vazquez appealed the dismissal, arguing that the state court’s dismissal based on state forum non conveniens could not bar a federal court from determining whether federal maritime law applied to his case.  The United States Eleventh Circuit Court of Appeals began by analyzing the applicability of Rooker-Feldman.  The court explained that, under this doctrine, the United States Supreme Court’s appellate jurisdiction over state-court judgments divests a federal district court of subject-matter jurisdiction over a matter it could otherwise adjudicate. The doctrine prevents the lower federal courts from becoming courts of appeal for state court decisions.  In this case, however, Vasquez was not seeking review of the state court’s decision. Vazquez sought review of the district court’s order that federal maritime law did not apply, an issue on which the state court did not rule.

The court next addressed the employer’s argument that Vasquez was precluded from re-litigating factual issue determined by the state court under the doctrine of collateral estoppel.  The court explained that the doctrine does not apply unless an issue was fully litigated and determined by a final decision of a court of competent jurisdiction and the parties and issues involved in the second proceeding are identical.  Here, the issues in the two proceedings were not identical.  In the federal court proceeding, Vasquez sought to litigate the applicability of federal maritime law and federal venue in the Southern District of Florida, while the state court proceeding dismissed his complaint under the state’s doctrine of forum non conveniens.

The court also rejected the employer’s argument that Vasquez’s claims were barred by res judicata.  That doctrine would only apply if the litigation in the previous proceeding resulted in a judgment on the merits.  The state court’s dismissal on the basis of forum non conveniens was not an adjudication of the merits but, rather, was a refusal to exercise jurisdiction while permitting the parties to litigate elsewhere.  The Eleventh Circuit vacated the decision of the district court and remanded for consideration of whether federal maritime law applied to Vasquez’s claims.

Vasquez v. YII Shipping Co., Ltd., — F.3d —, 2012 WL 3740435 (11th Cir. 8/30/12).


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