U.S. District Court for D.C. Addresses Claim Preclusion
In Scott v. WMATA, No. 24-cv-00487 (D.D.C. Dec. 2, 2024), the United States District Court for the District of Columbia dismissed the plaintiff’s negligence claim under the doctrines of res judicata and compulsory counterclaims, highlighting the difference between state and federal courts regarding counterclaims.
Background
The case arose from a multi-vehicle traffic incident that occurred in November 2021, involving Scott, Harden, and a WMATA driver. Harden initially filed a negligence suit in Maryland state court, which WMATA removed to the United States District Court for Maryland (“Maryland Case”). Harden later amended her complaint to include Scott as a defendant, and Scott filed an answer. The parties ultimately reached a settlement agreement, and the court entered a settlement order, dismissing all claims and counterclaims with prejudice after 30 days without further action.
In 2024, Scott brought a new negligence suit against the parties in D.C. Superior Court, which was subsequently removed to the U.S. District Court for D.C. Defendant Harden moved to dismiss the case, arguing it was barred by the settlement order entered in the Maryland case.
Analysis
The court held that the settlement order in the Maryland case constituted a final judgment on the merits. A dismissal with prejudice—whether by settlement or adjudication—precludes future litigation of claims that were or could have been raised in the earlier action. While Scott argued the Maryland court did not adjudicate negligence on its merits, the court clarified that factual findings are not required for claim preclusion to apply.
The court also addressed the issue of compulsory counterclaims. Federal Rule of Civil Procedure 13(a) requires a defendant to bring any counterclaims arising out of the same transaction or occurrence as the opposing party’s claim. Here, Scott’s negligence claim arose from the same traffic incident as Harden’s prior negligence claim.
Scott argued that Maryland state rules—which do not require compulsory counterclaims—should govern. However, the court held that federal procedural rules apply in federal court, even when jurisdiction arises from removal. Once Scott answered Harden’s amended complaint in federal court, Rule 13(a) applied, making his negligence claim compulsory. As a result, Scott was barred from pursuing his negligence claim in a subsequent suit in federal court.
Conclusion
This case underscores the importance of understanding both state and federal civil procedure rules—and knowing when each applies. While a claim may begin in state court, removal to federal court triggers the application of the Federal Rules of Civil Procedure, which can significantly affect a case. Here, although Maryland does not require compulsory counterclaims, once the case was removed, Federal Rule 13(a) applied, making Scott’s counterclaim mandatory. Practitioners must be mindful of how procedural rules shift upon removal and the potential impact on their claims.
