SHANDS TEACHING HOSPITAL AND CLINICS, INC., APPELLANT,
v.
BEECH STREET CORPORATION AND UNISYS CORPORATION, APPELLEES
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Trial court erred in applying res judicata to bar a state court action where the federal court dismissed on Eleventh Amendment immunity grounds, which does not preclude subsequent state court litigation.
A party is not precluded by res judicata from filing a state court action when the federal court dismissed the suit solely on Eleventh Amendment immunity grounds.
[1] Eleventh Amendment immunity dismissals in federal court do not support res judicata in subsequent state court proceedings because immunity is jurisdictional rather than a…
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Join FLexlaw to unlock all legal intelligence“Res judicata only applies to questions actually litigated and determined by or essential to the judgment rendered in the former proceedings.”
Court explaining that Eleventh Amendment immunity dismissals do not support res judicata because the immunity is jurisdictional, not a merits determination.
Shands Teaching Hospital filed suit against Beech Street Corporation and Unisys Corporation in federal court. The federal district court dismissed on …
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PER CURIAM.
In this appeal from a final summary judgment, we conclude that the trial court erred in finding the action commenced below barred by the rule of preclusion. In an earlier federal action brought by appellant, Shands Teaching Hospital and Clinics, Inc., against appellees, Beech Street Corp. and Unisys Corp., the United States District Court for the Northern District of Florida found the suit barred on Eleventh Amendment grounds and determined “this suit may only be brought in state court.” See Shands Teaching Hosp. & Clinics, Inc. v. Beech St. Corp. and Unisys Corp., No. GCA 98cv87 MMP (N.D.Fla. Jan. 5, 1999) (unpublished order).
On appeal, the Eleventh Circuit affirmed the district court’s decision. See Shands Teaching Hosp. & Clinics, Inc. v. Beech St. Corp., Unisys Corp., 208 F. 3d 1308 (11th Cir. 2000).
Because the federal decisions were based on Eleventh Amendment immunity, Shands was not precluded from filing the action in state court. See Trammell v. State, 622 So. 2d 1257, 1261 (Miss.1993) (“It is clear from a review of the record that Eleventh Amendment immunity was the sole reason for dismissal of the federal suit. Res judicata may not rest on such a tenuous premise. Res judicata only applies to questions actually litigated and determined by or essential to the judgment rendered in the former proceedings.”).
We do not reach any other matters argued by the parties. REVERSED and REMANDED for further proceedings.
WOLF, KAHN and BENTON, JJ., concur.
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Shands Teaching Hosp. & Clinics v. Beech St. Corp. & Unisys Corp., 899 So. 2d 1222 (Fla. 1st DCA 2005)…al, we reversed, holding that “[bjecause the federal decisions were based on Eleventh Amendment immunity, Shands was not precluded from filing the action in state court.” See Shands Teaching Hosp. & Clinics, Inc. v. Beech St. Corp. and Unisys Corp., 820 So. 2d 979, 979 (Fla. 1st DCA 2002). Proceedings on remand from our initial decision led to the second supplemental and amended complaint (the complaint), which the trial court dismissed as to Uni-sys,2 giving rise to the present appeal. We now review the pro…
Authorities Cited
- Shands Teaching Hosp. & Clinics, Inc. v. Beech St. Corp., 208 F.3d 1308 (11th Cir. 2000)