Simmons v. Trans Express Inc., No. 19-438 (2d Cir. 2020)Annotate this Case
The Second Circuit certified a question of New York law to the New York Court of Appeals: Under New York City Civil Court Act 1808, what issue preclusion, claim preclusion, and/or res judicata effects, if any, does a small claims court's prior judgment have on subsequent actions brought in other courts involving the same facts, issues, and/or parties? In particular, where a small claims court has rendered a judgment on a claim, does Section 1808 preclude a subsequent action involving a claim arising from the same transaction, occurrence, or employment relationship?