Krisor v. Lake County Fair Board

A court may apply a transactional approach to determine claim preclusion and separate related claims when they are not connected by the same factual transaction.

Krisor appeals the trial court’s decision to grant Lake County Fair Board’s motion for summary judgment. The Lake County Fair Board placed an advertisement in a local newspaper seeking to hire a technician. Krisor applied, but later learned that the board hired Haffner for the position. Krisor claimed (Krisor II) that the board rejected his application because he previously complained that the board conducted unlawful hiring practices. In a separate complaint (Krisor I), Krisor asserted a claim against the board members and sought a judgment to declare that Haffner’s hiring was void. The trial court granted a motion for summary judgment and held that Krisor’s complaint in Krisor I was not filed within the statute of limitations. Subsequently, the trial court concluded that Krisor II was precluded by the final judgment in Krisor I. The Court applied a “transactional” approach where two claims, connected by the same factual transaction, cannot be separated. While both claims stem from the board’s employment practices, both claims involve facts from different time periods. The Court held that Krisor’s claim was not from the same factual transaction that was litigated in Krisor I, and the trial court erred in allowing summary judgment. Reversed and Remanded.