St. Jude Medical S.C., Inc. v. Cormier, No. 13-2147 (8th Cir. 2014)
Annotate this CaseSt. Jude sued its competitor, Medtronic, for tortiously interfering with its business relationship with an employee. After the parties arbitrated their claims, St. Jude then sued the employee's wife (defendant) for related claims. On appeal, St. Jude challenged the district court's grant of summary judgment in favor of defendant. Defendant had left her at-will employment with St. Judge to work for Medtronic and her husband's sales at St. Jude dropped significantly. As a preliminary matter, the court concluded that Florida law applied because Florida was the forum that rendered the arbitration judgment. Applying Florida's requirements for res judicata, the court reversed the district court's dismissal of Counts 1, 3, 5, and 6 arising from defendant's acts as a St. Jude employee because they were not barred by res judicata; the court affirmed the district court's dismissal of Counts 2 and 4; and the court remanded for further proceedings.
Court Description: Civil case - Tortious Interference with Business Relationships. In an action alleging defendant, St. Jude's former employee, tortiously interfered with St. Jude's business interests with her husband, its employee, the portions of the claim dealing with defendant's acts while she was St. Jude's employee were not collaterally estopped by St.Jude's arbitration with Medtronic, her current employer; however, the portion of the claim dealing with her acts while she was a Medtronic employee were barred by collateral estoppel.
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