Riceland Foods v. Downing, No. 14-3758 (8th Cir. 2016)
Annotate this CasePlaintiffs filed a class action against Riceland, requesting the district court compel Riceland to contribute a portion of its recoveries in various cases to the common benefit fund established by the district court to compensate plaintiffs for their legal work. The district court dismissed Riceland's counterclaims of breach of contract and tortious interference and certified the dismissal as a final judgment under FRCP 54(b). The court agreed with its sister circuits and held that a res judicata effect can properly be considered as a “miscellaneous factor” under the Hayden factor analysis. In this case, the district court did not err in considering the res judicata ramification in the Arkansas state court case. The district court found that plaintiffs and the district court itself would suffer injustice if entry of final judgment was delayed. On the merits, the court concluded that the claims regarding genetically-modified rice were released by the Settlement Agreement and Release, but the Release does not govern plaintiffs’ unjust enrichment and quantum meruit claims against Riceland for its failure to contribute to the fund. Accordingly, the court affirmed the district court's judgment.
Court Description: Shepherd, Author, with Loken and Benton, Circuit Judges] Civil case - Genetically Modified Rice Litigation. The district court properly considered the factors involved in granting Rule 54(b) certification, including whether the district court and the plaintiffs would suffer injustice if entry of final judgment were delayed and the possible res judicata effect of a final judgment in state litigation, and did nor err in certifying the dismissal of Riceland's counterclaim as a final judgment under Rule 54(b); turning to the merits, the district court did not err in dismissing Riceland's counterclaim.
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