Wojciechowski v. Kohlberg Ventures, LLC, No. 17-15966 (9th Cir. 2019)
Annotate this Case
The settlement agreement—and in particular, the intent of the settling parties—determines the preclusive effect of the previous action. The settlement agreement in this case released plaintiff's and the class's claims against various parties, but it explicitly did not release any claims against Kohlberg.
The Ninth Circuit held that, because the settlement specifically did not release plaintiff's and the class's claims against Kohlberg, claim preclusion did not bar plaintiff's current claim. Therefore, the district court erred by dismissing the action on claim preclusion grounds. The panel reversed and remanded for further proceedings.
Court Description: Labor Law / Claim Preclusion Reversing the district court’s dismissal, the panel held that claim preclusion did not bar a claim against Kohlberg Ventures, LLC, under the Worker Adjustment Retraining and Notification Act because a settlement agreement approved by the bankruptcy court in a prior class action did not release any claims against Kohlberg. The panel concluded that the parties in the bankruptcy proceeding did not intend their settlement to extend to Kohlberg. Accordingly, claim preclusion did not bar plaintiff’s WARN Act claim against Kohlberg. The panel remanded the case for further proceedings.
Some case metadata and case summaries were written with the help of AI, which can produce inaccuracies. You should read the full case before relying on it for legal research purposes.
This site is protected by reCAPTCHA and the Google Privacy Policy and Terms of Service apply.