McConnell v. Travelers Indemnity Co.

Louisiana residents Mr. and Mrs. Archie McConnell (plaintiffs) were injured in a car accident. Under Louisiana law, Mrs. McConnell’s personal-injury claim was separate property, meaning it belonged to her alone. In contrast, Mr. McConnell’s personal-injury claim and both spouses’ claims for medical expenses were community property, meaning they belonged to both spouses. Because the husband, Mr. McConnell was considered master of the community, only he could sue on the community’s claims. Mrs. McConnell filed her personal-injury claim against insurance companies Travelers Indemnity Company and Employers Casualty Company (the companies) (defendants) in Louisiana state court. Mr. McConnell joined the suit to assert the community’s claim for Mrs. McConnell’s medical expenses. Mr. McConnell then filed a separate suit in federal court against the companies, asserting the community’s claim for his own personal injuries and his medical expenses. The companies moved to dismiss, arguing that Louisiana law did not allow Mr. McConnell to split his claim, seeking to recover for his wife’s medical expenses in state court and his own expenses and personal-injury damages in federal court. In response, Mr. McConnell asked the state court to dismiss his state-court claim with prejudice. The court did so, prompting the federal court to deny the companies’ motion to dismiss. However, the companies filed a second motion to dismiss, this time arguing that under Louisiana law, the dismissal with prejudice was effectively a final judgment as to Mr. McConnell’s entire claim, even the parts not asserted in state court. Consequently, res judicata, which bars the relitigation of claims already decided, precluded Mr. McConnell’s federal action. The district court granted the companies’ motion, and Mr. McConnell appealed.