Lynch v. Nat'l Prescription Admin., No. 14-2078 (8th Cir. 2015)
Annotate this CaseIn 2002, ESI acquired NPA, which provided pharmacy-benefit-management services to health funds created by the police union. In 2003, those funds brought a class action against ESI and NPA. The funds had never contracted with ESI. In 2004, the New York Attorney General sued ESI, resulting in a consent judgment. Based on that consent judgment, ESI moved for summary judgment in the funds’ suit. The district court granted ESI’s motion, applying res judicata. The Eighth Circuit reversed and remanded. ESI argued that the AG “alleged claims on behalf of the” funds, but the funds were not parties to the AG’s suit, nor did the AG allege claims on their behalf. The AG complaint referred to “other New York government plans,” meaning “counties and municipalities that contract with ESI.” The funds did not contract with ESI and are neither a county nor a municipality. They are private trusts. Their trustees are union officers, not city officials with whom they bargain.
Court Description: Benton, Author, with Smith and Shepherd, Circuit Judges] Civil case - Civil procedure. The plaintiff health funds were not parties to a suit between the Attorney General of the State of New York and defendant ESI, and the plaintiffs' action is not barred by the doctrine of res judicata since there is no privity between the Funds and the Attorney General.
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