Inman v. Ross

40 Pa. D. & C.4th 186, 1998 Pa. Dist. & Cnty. Dec. LEXIS 43
CourtPennsylvania Court of Common Pleas, Lawrence County
DecidedMarch 10, 1998
Docketno. 10663 of 1994, C.A.
StatusPublished

This text of 40 Pa. D. & C.4th 186 (Inman v. Ross) is published on Counsel Stack Legal Research, covering Pennsylvania Court of Common Pleas, Lawrence County primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Inman v. Ross, 40 Pa. D. & C.4th 186, 1998 Pa. Dist. & Cnty. Dec. LEXIS 43 (Pa. Super. Ct. 1998).

Opinion

PRATT, J.,

The plaintiff has presented the court with a motion in limine requesting that the court preclude the defendants from presenting any evidence relating to any alleged willful misconduct on the part of the plaintiff in being discharged or terminated by his former employer, defendant New Castle Home Medical, which contract of employment was subsequently assigned to defendant Tri-Medical Rehab Supply Inc.

The plaintiff’s motion is premised on the theory of res judicata in the nature of collateral estoppel or issue preclusion. The plaintiff contends that the ruling by the unemployment compensation referee on October 7,1994, after a full hearing of plaintiff’s unemployment compensation claim, that the plaintiff did not commit any willful misconduct, thereby entitling the plaintiff to unemployment compensation benefits for being terminated by the defendants, prevents the defendants from litigating the same issue in the instant case. Plaintiff argues that the same parties to the instant cause of action were afforded the opportunity during full hearings of the unemployment compensation claim to present evidence, examine witnesses, and present legal arguments, and that the unemployment compensation referee’s findings of fact and conclusions of law prohibit the defendants, in this case, from relitigating the same issues in this case. Consequently, plaintiff asserts that the decision by the unemployment compensation referee is conclusive of the issue of whether the plaintiff committed willful misconduct to justify his termination. [188]*188This in turn, plaintiff argues, prevents defendants from presenting any evidence relevant to that issue.

The main thrust of plaintiff’s argument is grounded on the ruling in Frederick v. American Hardware Supply Co., 387 Pa. Super. 72, 557 A.2d 779 (1989), as cited in both his memorandum of law in support of motion in limine and supplemental brief in support of motion in limine. In that case, the opinion by Judge Joseph Del Sole, reasoned that, since the issue decided in the unemployment compensation proceedings in that case was the same as the issue being litigated in the later civil cause of action, the judgment of the Unemployment Compensation Board of Review estopped the parties from relitigating the same issue in the civil cause of action. The Superior Court found that all of the elements necessary for applying collateral estoppel were present except the issue of whether the issue litigated in unemployment compensation proceedings was the same or identical to the issue raised or dispositive in the civil cause of action. Having found that the issues were the same, the Superior Court concluded that the doctrine of res judicata, as to issue preclusion under collateral estoppel, prevented the relitigation of the same issue in the later civil cause of action.

Defendants, however, cite the recent case of Rue v. K-Mart Corporation, 456 Pa. Super. 641, 691 A.2d 498 (1997), as a basis for their contention that the prior unemployment compensation litigation and rulings do not preclude the defendants from presenting similar evidence and relitigating its issue of whether the plaintiff was wrongfully discharged in the instant case.

After reviewing the plaintiff’s memorandum of law and supplemental brief and the defendants’ memorandum of law in opposition to the plaintiff’s motion in limine and the Rue v. K-Mart Corporation case and [189]*189counsel’s oral arguments, this court concludes that, because the Superior Court in the Rue case based its decision on an entirely different theory from that in the earlier Frederick case, the Rue holding is dispositive of plaintiff’s motion.

In Frederick, the court of common pleas case was a breach of an employment contract action for discharging an employee for willful misconduct, whereas in Rue, the civil action was based on defamation against the plaintiff’s employer, the defendant, for allegedly publicizing the plaintiff’s conduct, which supposedly justified the defendant’s action in terminating the plaintiff’s employment.

In Rue, the basis for the Superior Court’s decision was articulated as follows:

“[W]e are not convinced that the facts found in the unemployment compensation case merit preclusive effect in the present defamation action because of the vastly differing policy considerations underlying the two actions. In other words, the different policy concerns between the unemployment compensation system and civil actions mandate two vastly different methods of adjudicating facts, and, thus, we conclude that the unemployment compensation process does not provide a party with the ‘full and fair opportunity to litigate the issue in question’ necessary for the application of collateral estoppel.” Id. at 646-47, 691 A.2d at 500-501.

Thus, the Superior Court in Rue held that collateral estoppel did not preclude relitigating the issue of the plaintiff’s misconduct in the defamation action on the basis that the issue was previously litigated and judgment entered in the unemployment compensation proceedings involving the same parties.

Citing the four conditions which must be met before issue preclusion may be appropriately invoked, includ[190]*190ing identity of issues and full and fair opportunity to litigate the issue in the prior action, the court in Rue found that it must not merely decide whether the factual determination made in the plaintiff’s unemployment compensation proceeding, on its face, is sufficiently similar to that in the subsequent civil cause of action to merit a preclusion effect via collateral estoppel, but must also determine whether the defendant against whom collateral estoppel was being asserted had a full and fair opportunity to litigate the issue on its merits in the prior unemployment compensation proceeding. The Superior Court, without deciding whether the issue before the unemployment compensation proceeding and the civil cause of action were similar, held that it was “convinced that ‘fast and informal’ nature of the proceedings do not afford a ‘full and fair opportunity to litigate the issue in question’ in the same manner that a [sic] would result from a trial in the court of common pleas.” Id. at 658, 691 A.2d at 506. The court also opined that,

“Increased litigation of unemployment compensation claims caused by the possibility of collateral estoppel in subsequent litigation would seriously jeopardize the unemployment compensation systems [sic] ability to meet its goal of prompt financial support to those persons unemployed through no fault of their own. That alone would be reason enough to refuse to grant preclusive effect to unemployment compensation decision [sic].” Id. at 657-58, 691 A.2d at 506.

The court concluded by stating:

“In sum, we will not approve the lower court’s grant of issue preclusion in this case. To do so would be to hold, in effect, that appellee loses the defamation suit based upon the finding of an unemployment compensation referee, even though significantly different [191]*191procedures apply and different policies and goals are at stake in the unemployment compensation proceeding.

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Related

Krause v. Great Lakes Holdings, Inc.
563 A.2d 1182 (Supreme Court of Pennsylvania, 1989)
Rue v. K-Mart Corp.
691 A.2d 498 (Superior Court of Pennsylvania, 1997)
Frederick v. American Hardware Supply Co.
557 A.2d 779 (Supreme Court of Pennsylvania, 1989)

Cite This Page — Counsel Stack

Bluebook (online)
40 Pa. D. & C.4th 186, 1998 Pa. Dist. & Cnty. Dec. LEXIS 43, Counsel Stack Legal Research, https://law.counselstack.com/opinion/inman-v-ross-pactcompllawren-1998.