Midwest Disability Initiative v. JANS Enterprises, Inc., No. 18-1086 (8th Cir. 2019)
Annotate this CaseMDI, a Minnesota nonprofit organization, and one of its members filed suit under Title III of the Americans with Disabilities Act, seeking declaratory and injunctive relief. The Eighth Circuit affirmed the district court's motion to dismiss the action based on res judicata grounds, because the action was precluded by the final judgment on the merits in a prior suit by MDI and one of its members. The court explained that the dismissal of the second suit was a product of MDI's decision to assert associational standing claims as a co-plaintiff on behalf of its members in the MDI-Testa suit and then to dismiss its representational claims on the merits. The court noted that the only nonparty individuals bound by these tactics are members of MDI at the time.
Court Description: Loken, Author, with Colloton and Kelly, Circuit Judges] Civil case - Americans with Disabilities Act. The district court properly granted the motion to dismiss this action because it is precluded by the final judgment in an action brought by MDI and another of its members; the dismissal of this second suit was a product of MDI's decision to assert associational standing claims as a co-plaintiff on behalf of its members in the first action and then to dismiss its representational claims on the merits.
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