Alexander Moskovits v. Mercedes-Benz Financial Services

CourtMichigan Court of Appeals
DecidedMay 16, 2025
Docket370802
StatusUnpublished

This text of Alexander Moskovits v. Mercedes-Benz Financial Services (Alexander Moskovits v. Mercedes-Benz Financial Services) is published on Counsel Stack Legal Research, covering Michigan Court of Appeals primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Alexander Moskovits v. Mercedes-Benz Financial Services, (Mich. Ct. App. 2025).

Opinion

If this opinion indicates that it is “FOR PUBLICATION,” it is subject to revision until final publication in the Michigan Appeals Reports.

STATE OF MICHIGAN

COURT OF APPEALS

ALEXANDER MOSKOVITS, UNPUBLISHED May 16, 2025 Plaintiff-Appellant, 9:51 AM

v No. 370802 Oakland Circuit Court MERCEDES-BENZ FINANCIAL SERVICES USA, LC No. 2023-201552-CZ LLC,

Defendant-Appellee.

Before: GADOLA, C.J., and MURRAY and REDFORD, JJ.

PER CURIAM.

Plaintiff appeals as of right the order granting defendant’s motion for summary disposition under MCR 2.116(C)(7) (dismissal appropriate because of prior judgment). We affirm.

I. BACKGROUND AND PROCEDURAL HISTORY

This case arose when plaintiff purchased a Mercedes-Benz CLA (the vehicle) from Mercedes-Benz Miami on January 13, 2017. Plaintiff financed a portion of the cost of the vehicle with defendant, agreeing to make monthly payments. Once purchased, plaintiff drove the vehicle to Mexico, where it was damaged. Plaintiff delivered the vehicle to a repair shop in Mexico. After issues and delays with the repair shop, plaintiff returned to the United States, leaving the vehicle in Mexico.

Once in the United States, plaintiff contacted defendant and requested it transport the vehicle to the United States. Defendant declined, and plaintiff stopped making his monthly payments. Defendant repossessed the vehicle in Mexico, transported it to the United States, and auctioned the vehicle in Texas, without notifying plaintiff.

Plaintiff later sued defendant in the United States District Court for the Southern District of Texas. Plaintiff alleged (1) a violation of the Texas Deceptive Trade Practices Act (“DTPA”), Tex Bus & Com Code § 17.41 et seq.; (2) violations of the Texas Debt Collection Practices Act (“DCPA”), Tex Fin Code § 392.001 et seq.; (3) conversion; and (4) civil theft. Defendant moved to dismiss plaintiff’s claims under FR Civ P 12(b)(4) (insufficient process), 12(b)(5) (insufficient

-1- service of process), and 12(b)(6) (failure to state a claim upon which relief can be granted). The federal district court granted defendant’s motion to dismiss,1 and the Fifth Circuit Court of Appeals affirmed.2

While his appeal was pending in the Fifth Circuit, plaintiff filed this suit, alleging a violation of the Michigan Consumer Protection Act (“MCPA”), MCL 445.901 et seq., and a breach-of-contract claim. Plaintiff raised the same factual basis delineated in federal court for his claims in Michigan. In lieu of an answer, defendant moved for summary disposition under MCR 2.116(C)(7), arguing plaintiff’s claims were precluded under the doctrine of res judicata. In response, plaintiff moved for summary disposition under MCR 2.116(C)(7) and (C)(10), and he denied his claims arose from the same set of facts as his federal claims. The trial court granted defendant’s motion for summary disposition, finding plaintiff’s claims arose from the same set of facts as the federal case.

Plaintiff moved for reconsideration, arguing res judicata was incorrectly applied and should have been precluded under the doctrine of equitable estoppel. The trial court denied plaintiff’s motion for reconsideration, finding he failed to demonstrate palpable error. This appeal followed.

II. DEFENDANT’S MOTION FOR SUMMARY DISPOSITION

Plaintiff argues the trial court erred when it applied res judicata and granted defendant’s motion for summary disposition.3

A. STANDARDS OF REVIEW

“We review de novo both a trial court’s decision on a motion for summary disposition and its application of the legal doctrine of res judicata.” Garrett v Washington, 314 Mich App 436, 440-441; 886 NW2d 762 (2016). “In making this determination, the Court reviews the entire record to determine whether defendant was entitled to summary disposition.” Maiden v Rozwood, 461 Mich 109, 118; 597 NW2d 817 (1999). “MCR 2.116(C)(7) permits summary disposition because of release, payment, prior judgment, [or] immunity granted by law.” Clay v Doe, 311 Mich App 359, 362; 876 NW2d 248 (2015) (quotation marks and citation omitted). “When reviewing a motion under MCR 2.116(C)(7), the trial court must accept as true all of the plaintiff’s well-pleaded factual allegations and construe them in favor of the plaintiff unless disputed by

1 Moskovits v Mercedes-Benz Fin Servs USA, LLC, unpublished order of the United States District Court for the Southern District of Texas, entered August 31, 2022 (Case No. 4:21-cv-02260). 2 Moskovits v Mercedes-Benz Fin Servs USA, LLC, unpublished per curiam opinion of the United States Court of Appeals for the Fifth Circuit, issued October 23, 2023 (Case No. 22-20522). 3 It appears plaintiff also challenges the trial court’s ruling on his motion for reconsideration. However, plaintiff failed to raise this issue in his statement of questions presented. Consequently, this issue is waived. See English v Blue Cross Blue Shield of Mich, 263 Mich App 449, 459; 688 NW2d 523 (2004) (“An issue not contained in the statement of questions presented is waived on appeal.”). However, we note the trial court did not err in its legal analysis regarding plaintiff’s ability to aggregate his claims in the federal district court.

-2- documentary evidence submitted by the moving party.” Norman v Dep’t of Transp, 338 Mich App 141, 146; 979 NW2d 390 (2021). “A party may support a motion under MCR 2.116(C)(7) by affidavits, depositions, admissions, or other documentary evidence.” Maiden, 461 Mich at 119. “The contents of the complaint are accepted as true unless contradicted by documentation submitted by the movant.” Id. “Equitable issues are reviewed de novo, but we review for clear error the court’s findings of fact supporting its decision.” AFSCME Int’l Union v Bank One, 267 Mich App 281, 293; 705 NW2d 355 (2005).

B. ANALYSIS

Plaintiff argues the trial court erred when it allowed defendant to raise the defense of res judicata and when it failed to apply the doctrine of equitable estoppel.

The parties rely on the federal test for whether res judicata applied. And for good reason, as both this Court and the Supreme Court have held that the federal res judicata test applies to determine the preclusive effect of a federal judgment. See Pierson Sand & Gravel, Inc v Keeler Brass Co, 460 Mich 372, 380–381; 596 NW2d 153 (1999) (“If a plaintiff has litigated a claim in federal court, the federal judgment precludes relitigation of the same claim in state court based on issues that were or could have been raised in the federal action, including any theories of liability based on state law. The state courts must apply federal claim-preclusion law in determining the preclusive effect of a prior federal judgment.”) (quotation marks and citation omitted); Beyer v Verizon North, Inc, 270 Mich App 424, 428-429; 715 NW2d 328 (2006) (same).

Defendant relied on Sacks v Tex Southern Univ, 83 F4th 340, 344 (CA 5, 2023), which provides the federal test for res judicata:

True res judicata—also called claim preclusion—applies only if (1) the parties are identical or in privity; (2) the judgment in the prior action was rendered by a court of competent jurisdiction; (3) the prior action was concluded by a final judgment on the merits; and (4) the same claim or cause of action was involved in both actions. [Id. (quotation marks and citation omitted).]

For the federal test, the last element requires that “the same claim or cause of action was involved in both actions.” Sacks, 83 F4th at 344. The transactional test is used when determining this last element. Id.

Plaintiff concedes the federal case reached a final judgment on the merits and the parties between the cases were identical.

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Bluebook (online)
Alexander Moskovits v. Mercedes-Benz Financial Services, Counsel Stack Legal Research, https://law.counselstack.com/opinion/alexander-moskovits-v-mercedes-benz-financial-services-michctapp-2025.