Papadopoulos v. Douglas

CourtCourt of Appeals for the Fifth Circuit
DecidedJuly 19, 2001
Docket00-20176
StatusUnpublished

This text of Papadopoulos v. Douglas (Papadopoulos v. Douglas) is published on Counsel Stack Legal Research, covering Court of Appeals for the Fifth Circuit primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

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Papadopoulos v. Douglas, (5th Cir. 2001).

Opinion

UNITED STATES COURT OF APPEALS For the Fifth Circuit

No. 00-20176

ANESTIS PAPADOPOULOS, doing business as Spoilers Etc.

Plaintiff-Appellant,

VERSUS

ANDREW JACKSON DOUGLAS, III, doing business as Andy’s Autosport; AUTOSPORT, INC.,

Defendants-Appellees.

Appeal from the United States District Court For the Southern District of Texas, Houston Division (H-99-CV-1114) July 18, 2001 Before GARWOOD, PARKER, and DENNIS, Circuit Judges. PER CURIAM:*

Anestis Papadopoulos appeals the district court order

dismissing his claims of copyright infringement (17 U.S.C. § 101 et

seq.), Lanham Act violations (15 U.S.C. § 1051 et seq.), and unfair

competition. We affirm the judgment of the district court.

I. Factual and Procedural History

* Pursuant to 5TH CIR. R. 47.5, the Court has determined that this opinion should not be published and is not precedent except under the limited circumstances set forth in 5TH CIR. R. 47.5.4.

1 Papadopolous, doing business as Spoilers Etc. (“Spoilers”),

began selling a variety of automobile accessories, including ground

effects kits, in 1986 in Texas. Andrew Jackson Douglas III, doing

business as Andy’s Autosport (“Autosport”), began manufacturing and

selling ground effects kits in 1980 in California.

In 1998, Autosport sued Spoilers for trademark infringement,

unfair competition, trademark dilution, injury to business

reputation, and deceptive trade practices in a California federal

court. Autosport alleged that Spoilers was duplicating Autosport’s

ground effects designs and infringing on Autosport’s trademarks

“Combat,” “The Bomb,” and “Andy’s Auto Sport” through the use of

Spoilers’ “Kamikaze” ground effects kit. The kits at issue were

manufactured for installation on the following cars: 1994-1998

Acura Integra, 1994-1997 Honda Accord, 1992-1995 Honda Civic, 1996-

1997 Honda Civic, 1992-1996 Honda Prelude, 1995-1997 Mitsubishi

Eclipse, 1995-1998 Nissan 200SX, and 1993-1997 Volkswagen Jetta.

Spoilers filed no counterclaims in this California action, which

was then set for trial. When Spoilers subsequently filed suit

against Autosport in a Texas federal court, the California district

court declined to issue an injunction; however, the court concluded

that Spoilers had asserted what amounted to a compulsory

counterclaim and expressed willingness to accept the transfer of

the Texas suit. In 1999, the California district court granted

summary judgment for Spoilers on some of Autosport’s claims, and in

2000, it granted judgment as a matter of law for Spoilers on the

2 remaining claims.

In 1999, Spoilers brought suit against Autosport in a Texas

federal court, alleging that Autosport had used Spoilers’ ground

effects designs and photographs in a Spoilers’ catalog and

attempted to sell Spoilers’ products as that of Autosport’s.

Spoilers also alleged that Autosport copied Spoilers’ designs and

sold “knock-off” ground effects kits. At issue in this suit were

kits manufactured for installation on the following cars: 1989-1994

Nissan Maxima, 1991-1994 Nissan 240SX, 1995-1999 Nissan 240SX,

1989-1991 Isuzu Amigo, 1992-1996 Isuzu Amigo, and 1990-1994

Mitsubishi Eclipse. The Texas federal district court granted

Autosport’s motion to dismiss on the basis that Spoilers’ claims

were barred as compulsory counterclaims required in the California

federal suit.

II. Standard of Review

This court reviews the district court's decision that the

claim was barred as a compulsory counterclaim de novo. Tank

Insulation Int’l, Inc. v. Insultherm, Inc., 104 F.3d 83, 86 (5th

Cir. 1997).

III. Analysis

Federal Rule of Civil Procedure 13(a) provides:

A pleading shall state as a counterclaim any claim which at the time of serving the pleading the pleader has against any opposing party, if it arises out of the transaction or occurrence that is the subject matter of the opposing party's claim and does not require for its adjudication the presence of third parties of whom the court cannot acquire jurisdiction. But the pleader need

3 not state the claim if (1) at the time the action was commenced the claim was the subject of another pending action, or (2) the opposing party brought suit upon the claim by attachment or other process by which the court did not acquire jurisdiction to render a personal judgment on that claim, and the pleader is not stating any counterclaim under this Rule 13.

“A counterclaim which is compulsory but is not brought is

thereafter barred[.]” Baker v. Gold Seal Liquors, Inc., 417 U.S.

467, 469 n.1 (1974); see also FED. R. CIV. P. 13 advisory committee’s

note (“If the action proceeds to judgment without the interposition

of a counterclaim as required by subdivision (a) of this rule, the

counterclaim is barred.”); McDaniel v. Anheuser-Busch, Inc., 987

F.2d 298, 304 (5th Cir. 1993) (citing Baker, 417 U.S. at 469 n.1);

Cleckner v. Republic Van & Storage Co., 556 F.2d 766, 768-69 (5th

Cir. 1977); 6 CHARLES ALAN WRIGHT, ARTHUR R. MILLER, & MARY KAY KANE, FEDERAL

PRACTICE AND PROCEDURE: CIVIL 2D § 1409 (2d ed. 1990) (“Perhaps the most

important characteristic of a compulsory counterclaim is that it

must be asserted in the pending case. A failure to do so will

result in its being barred in any subsequent action, at least in

the federal courts.”).

The Fifth Circuit has developed the following test for

determining if claims are compulsory counterclaims:

(1) whether the issues of fact and law raised by the

claim and counterclaim largely are the same; (2) whether

res judicata would bar a subsequent suit on defendant’s

claim absent the compulsory counterclaim rule; (3)

4 whether substantially the same evidence will support or

refute plaintiff’s claim as well as defendant’s

counterclaim; and (4) whether there is any logical

relationship between the claim and the counterclaim.

Park Club, Inc. v. Resolution Trust Corp., 967 F.2d 1053, 1058 (5th

Cir. 1992); see also 3 JAMES WM. MOORE ET AL., MOORE’S FEDERAL PRACTICE §

13.10[1][b] (3d ed. 2001). “An affirmative answer to any of the

four questions indicates the claim is compulsory.” Underwriters at

Interest on Cover Note JHB92M10482079 v. Nautronix, Ltd., 79 F.3d

480, 483 n.2 (5th Cir. 1996). The Fifth Circuit’s approach focuses

on whether the claim and counterclaim share an “aggregate of

operative facts,” drawing on the similarity of facts and legal

issues prong. 3, MOORE’S FEDERAL PRACTICE, supra, § 13.10[1][b] (citing

McDaniel, 987 F.2d at 303-04).

The issues of fact and law within the Texas and California

federal suits, while not identical, are largely the same. Most

important is the continuing business relationship that Spoilers and

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