McConnell v. Travelers Indemnity Co.

Facts

Two Louisiana residents, Mr. and Mrs. Archie McConnell (plaintiffs), were injured in a car accident. They brought suit against Travelers Indemnity Co. (Travelers) (defendant) for damages associated with medical expenses and personal injuries arising out of the accident. Mrs. McConnell and Mr. McConnell filed two separate suits in federal court seeking damages from Travelers. Mr. McConnell requested $85,000 for his personal injuries, and $352.50 to cover his medical expenses. Nearly two years later, Mr. McConnell filed a suit in state court for his medical expenses. Travelers filed a motion for summary judgment, alleging that Mr. McConnell had impermissibly split his claims between state and federal court. In response, while Travelers’ motion was pending, Mr. McConnell voluntarily dismissed his state claims with prejudice, and the district court judge denied Travelers’ motion. Travelers then filed a second motion for summary judgment, arguing that Mr. McConnell could have only pursued his claim for personal injuries by amending his state claim, but because he dismissed his claim in state court with prejudice, he had dismissed his entire claim. Travelers argued that, because Mr. McConnell had dismissed his entire claim, a final judgment was rendered with respect to his case, and therefore to proceed with the case in federal court would be res judicata. The district court granted Travelers’ motion, and Mr. McConnell appealed.

Rule of Law

Issue

Holding and Reasoning (Wisdom, J.)