Lucas v. Lake County

A suit between two parties is not barred by claim preclusion when there is prior litigation between the parties that arose from a different transaction. Additionally, a claim is wrongfully dismissed when the amended complaints were consistent in showing the discharge offends public policy.

Lucas appealed the district court’s dismissal of his American with Disabilities Act (ADA) wrongful termination of employment claim on the grounds that (1) the court erred in entering summary judgment on the basis of claim preclusion because of prior litigation between the parties; and (2) the court incorrectly found that termination did not offend public policy. Lucas asserted his claim for wrongful termination under the ADA in 2006, because he believed the terminated from his job as a deputy sheriff was related to his physical disability despite other issues that occurred. Lucas subsequently filed multiple extensions and motions to amend his complaint, hoping to assert other theories. The district court found that the other theories and claims were subject to dismissal on claim preclusion because they were on the same facts already asserted in the first federal suit. The Court of Appeals found that neither claim was barred by claim preclusion because it arose from a different transaction. After looking at Lucas’s duties as a sheriff and the facts of the situation, the Court also found that Lucas stated a valid claim that adequately pleaded that his dismissal offends public policy under his first claim. Reversed and remanded.