Summary
The Supreme Court of North Carolina affirmed dismissal of plaintiffs’ claims against several health insurers arising from alleged restrictions on chiropractic services and related antitrust conduct. The Court held that the claims were barred by collateral estoppel based on its decision in the companion case, Sykes v. Health Network Solutions, Inc. The opinion also notes that the Court was equally divided on certain antitrust and dependent civil conspiracy claims in the companion case, leaving the trial court’s decision affirmed without precedential value as to those claims.
Holdings
- Plaintiffs' claims were barred by collateral estoppel because the issues in this action were the same as those in Sykes I, were actually litigated there, were material and relevant to its disposition, and were necessary and essential to the resulting judgment.
- The trial court's order dismissing plaintiffs' claims was affirmed.
Questions Presented
- Whether plaintiffs' claims were barred by collateral estoppel because the same issues had been fully litigated and necessarily decided in the companion Sykes I action.
- Whether the trial court properly dismissed plaintiffs' complaint under Rule 12(b)(6).
Disposition
affirmed
Cases Cited (11)
- Sykes v. Health Network Solutions, Inc., ___ N.C. ___, ___ S.E.2d ___ (2019) (No. 251PA18)(applied)
- Bridges v. Parrish, 366 N.C. 539, 541, 742 S.E.2d 794, 796 (2013)(followed)
- Coley v. State, 360 N.C. 493, 494-95, 631 S.E.2d 121, 123 (2006)(followed)
- Thompson v. Waters, 351 N.C. 462, 463, 526 S.E.2d 650, 650 (2000)(quoted)
- King v. Grindstaff, 284 N.C. 348, 356, 358, 200 S.E.2d 799, 805-06 (1973)(followed)
- Whitacre P'ship v. Biosignia, Inc., 358 N.C. 1, 15, 591 S.E.2d 870, 880 (2004)(followed)
- Hales v. N.C. Ins. Guar. Ass'n, 337 N.C. 329, 333, 445 S.E.2d 590, 594 (1994)(followed)
- Comm'r v. Sunnen, 333 U.S. 591, 599, 68 S. Ct. 715, 720, 92 L. Ed. 898, 907 (1948)(quoted)
- Valley Liquors, Inc. v. Renfield Imps., Ltd., 822 F.2d 656, 666 (7th Cir.), cert. denied, 484 U.S. 977, 108 S. Ct. 488, 98 L. Ed. 2d 486 (1987)(discussed)
- Rebel Oil Co. v. Atl. Richfield Co., 51 F.3d 1421, 1434 (9th Cir.), cert. denied, 516 U.S. 987, 116 S. Ct. 515, 133 L. Ed. 2d 424 (1995)(discussed)
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