Ideker v. Harley-Davidson, Inc., No. 14-1331 (8th Cir. 2015)
Annotate this CaseIdeker sued, alleging she developed non-Hodgkins lymphoma from exposure to benzene while working in HD’s paint department. The district court dismissed, predicting that the Missouri Supreme Court would require Ideker to raise her claim before Missouri’s labor and industrial relations commission because it was covered by Missouri’s Workers’ Compensation Law. Ideker then filed a workers’ compensation claim, which is pending. The dismissal became final. Less than 30 days later, the Missouri Court of Appeals issued an opinion that cast doubt on that prediction. Although Ideker’s counsel was aware of the decision before time to appeal expired, counsel stated that “there was little incentive for Ideker to seek appellate review requiring a second federal court to predict how Missouri courts would rule.” Ideker filed a complaint in state court, reasserting her occupational disease claim. Harley-Davidson removed the case to federal court. The court dismissed without prejudice on collateral estoppel grounds, concluding that its prior decision was binding because Missouri law precluded Ideker “from relitigating issues finally decided in [an] incorrect order[].” The Eighth Circuit affirmed. Any purported “mistake” the court made in predicting Missouri law does not enable Ideker to circumvent the dismissal by refiling the same injury claim based on the same historical facts in a second case.
Court Description: Riley, Author, with Loken and Smith, Circuit Judges] Civil case - Civil Procedure. The district court's decision in a prior action between the parties holding that Missouri's labor and industrial relations commission had exclusive statutory authority to hear plaintiff's occupational disease claim was a final decision that can be given preclusive effect; plaintiff's argument that collateral estoppel does not apply in her case because of intervening decisions by the Missouri Court of Appeals is rejected as the district court did not err in determining that its prior decision, right or wrong, was preclusive; it would not be fundamentally unfair to apply collateral estoppel to the facts of the case.
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