Tripati v. Henman

Summary

The Ninth Circuit held that a district court judgment retains preclusive effect for res judicata purposes while an appeal or Rule 59(e) motion is pending. Because Tripati’s identical law-library claim had already been resolved in an earlier action, the court affirmed dismissal of the later action without reaching the underlying constitutional issue.

Holdings

1. A final judgment retains its res judicata consequences while an appeal is pending.
2. A pending Rule 59(e) motion does not deprive a judgment of finality for res judicata purposes.
3. The district court correctly held that its rejection of Tripati's law-library claim in the first action precluded consideration of the identical claim in the second action.

Questions Presented

1. Whether a judgment retains its res judicata consequences while an appeal is pending.
2. Whether a pending Rule 59(e) motion deprives a judgment of finality for res judicata purposes.
3. Whether the district court properly barred the identical law-library claim in the second action based on the judgment in the first action.

Disposition

affirmed