Powder Basin Psychiatric Associates, Inc. v. Ullrich
Idaho Court of Appeals
129 Idaho 658 (1996)
- Written by Mary Phelan D'Isa, JD
Facts
Powder Basin Psychiatric Associates, Inc. (plaintiff), the former employer of George J. Ullrich (defendant), sued Ullrich in state court in Idaho to recover office furniture that Ullrich wrongfully took after his employment was terminated. Powder Basin also alleged that Ullrich wrongfully took money that did not belong to him, but it failed to amend its complaint to add an additional claim for the money or seek an accounting. Thereafter, Powder Basin and Ullrich settled the furniture claim, and the case was dismissed with prejudice. Powder Basin then filed a second state-court action against Ullrich for the money and Ullrich counterclaimed and alleged unjust enrichment. The trial court granted Ullrich’s motion for summary judgment and dismissed Powder Basin’s claim under the doctrine of res judicata (claim preclusion). The trial court ultimately dismissed Ullrich’s counterclaim with prejudice. Powder Basin appealed and argued that claim preclusion should not have been applied to its money claim because it sought an expedited resolution of the furniture claim, which prevented it from asserting the money claim; that its money and furniture claims arose out of different transactional facts; and that dismissal of its claim was inequitable because it would be without a defense if Ullrich later pursued his counterclaim.
Rule of Law
Issue
Holding and Reasoning (Walters, C.J.)
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