Summary
The Rhode Island Supreme Court affirmed summary judgment for the defendant, holding that res judicata barred the plaintiff's tortious-interference claim. The court applied the transactional approach to claim preclusion, concluding that the second action arose from the same statements and transaction as the plaintiff's earlier, time-barred slander action.
Topics
Practice areas
Questions Presented
- Whether summary judgment was proper because the second action was barred by res judicata or claim preclusion.
- Whether changing the theory of liability from slander to tortious interference avoided claim preclusion.
- Whether Mills's contention that she could not previously have known the gravamen of the claim prevented application of the transactional rule.
Holdings
- The second action was barred by res judicata because it involved the same parties, followed a final judgment in the first action, and arose from the same transaction or series of connected transactions.
- A plaintiff cannot avoid res judicata merely by relabeling the same underlying conduct under a different theory of liability.
- Mills's assertion that she could not have known the gravamen of the claim when she filed the first action did not defeat res judicata.
Key quotations
“As such, plaintiff's second suit was barred by res judicata.” (916 A.2d at 757)
“Our transactional rule of claim preclusion "extinguish[es] a plaintiff's claim against a defendant even though the plaintiff would be prepared in a second action to present evidence or grounds or theories of the case not presented by the plaintiff in the first action, or to seek remedies or forms of relief not demanded in that action."” (916 A.2d at 757)
Factual background
Mills previously brought a slander action against Toselli based on comments allegedly made by Toselli at a May 2000 deposition in a Rhode Island medical-licensure proceeding. After that action was held barred by the one-year statute of limitations, Mills filed a second action alleging that Toselli intentionally interfered with prospective contractual relations, relying on virtually the same statements. The Rhode Island Supreme Court concluded that both actions arose from the same transaction or series of connected transactions.
Procedural history
Mills previously sued Toselli for slander based on statements allegedly made during a medical-licensure proceeding, but the Rhode Island Supreme Court affirmed summary judgment for Toselli because the slander action was untimely. Shortly thereafter, Mills filed a second action asserting tortious interference with prospective contractual relations based on substantially the same statements. The Superior Court granted Toselli summary judgment on res judicata grounds, and the Supreme Court affirmed after determining that no cause had been shown for summary disposition.