Finstad v. Beresford Bancorporation, Inc., No. 15-2814 (8th Cir. 2016)
Annotate this CasePlaintiffs filed suit alleging that Beresford breached the terms of an option contract by selling their former farm to the Gords. Plaintiffs also claim that the Gords tortiously interfered with their contract with Beresford. The district court granted summary judgment for Beresford and the Gords based on the preclusive effect of a prior state-court judgment. The court concluded that the doctrine of claim preclusion bars plaintiffs' claims against Beresford where the state court's grant of summary judgment in Finstad I was on the merits, this federal case involves the same parties as Finstad I, and plaintiffs' claim of judicial estoppel was rejected. Plaintiffs brought two claims in Finstad I and the state district court entered separate conclusions of law on these two claims. These two conclusions were not alternative holdings; each resolved a separate claim in the complaint. Therefore, in affirming the grant of summary judgment for the Gords on all claims, the state supreme court affirmed both conclusions. Because the Finstad I court necessarily decided that plaintiffs lacked a contractual interest in the farmland, plaintiffs are barred from relitigating that issue here. Accordingly, the court affirmed the judgment.
Court Description: Colloton, Author, with Smith, Circuit Judge and Gritzner, District Judge] Civil Case - diversity. District court's properly dismissed action for breach of contract, conversion, interference with contract and tort against Beresford Bancorporation based on doctrine of claim preclusion under North Dakota law, as prior state court action was a decision on the merits, involved the same parties, and the federal claims could have been raised in the state court action. The district court also properly granted summary judgment to the Gords based on issue preclusion, as the state court decision was on the merits and the state court decided that the Finstads did not have an interest in the property and thus could not relitigate that issue in federal court.
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