Ruiz v. Snohomish County PUD, No. 14-35030 (9th Cir. 2016)
Annotate this CasePlaintiff filed suit against Defendant Jim Little, the Executive Director of Employee Relations at the District, alleging sex discrimination for acts that had occurred in 2008. The district court dismissed the suit with prejudice based on lack of personal jurisdiction and untimeliness. Plaintiff later filed suit in 2013 against Little and the District, alleging sex discrimination claims, under state and federal law, stemming in part from her termination in 2010. The district court held that the earlier dismissal was res judicata and barred this action. The court held - consistent with the Restatement (Second) of Judgments and at least three sister circuits - that an earlier dismissal on alternative grounds, where one ground is a lack of jurisdiction, is not res judicata. Therefore, the court concluded that res judicata does not bar this action. The court reversed the dismissal in part. The court affirmed the dismissal of plaintiff's federal claim because plaintiff's lawyer clearly and expressly abandoned the claim. The court affirmed the dismissal of plaintiff's state-law claims to the extent that they rely solely on events that occurred more than three years before the filing of the complaint in this case. For purposes of the motion to dismiss, at least two claims are timely: (1) plaintiff's claim alleging discriminatory firing in 2010; and (2) a hostile work environment claim founded in part on actions occurring within the limitations period. The court remanded.
Court Description: Civil Rights / Res Judicata. The panel affirmed in part and reversed in part the district court’s dismissal, on res judicata grounds, of an action brought under 42 U.S.C. § 1983 and state law, alleging sex discrimination. Plaintiff sued her former employer in 2011, alleging sex discrimination for acts that occurred in 2008. The district court dismissed that action “with prejudice” on two grounds: lack of personal jurisdiction and untimeliness. In 2013, plaintiff brought the present action, alleging sex discrimination claims, under state and federal law, stemming in part from her termination in 2010. The district court held that the earlier dismissal was res judicata and that, accordingly, it barred the present action. The panel held that – consistent with the Restatement (Second) of Judgments and at least three sister circuits – an earlier dismissal on alternative grounds, where one ground is a lack of jurisdiction, is not res judicata. The panel therefore held that res judicata did not bar this action. The panel determined, however, that dismissal of some of plaintiff’s claims was proper on other grounds, and therefore the panel affirmed in part, reversed in part and remanded for further proceedings. RUIZ V. SNOHOMISH CTY. PUD 3
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