Richard Turlington v. Savannah River Nuclear Solutions, LLC

Summary

The United States District Court for the District of South Carolina considers whether res judicata bars Richard Turlington’s Title VII claims alleging religious discrimination and failure to accommodate related to Savannah River Nuclear Solutions, LLC’s COVID-19 vaccination mandate. The court analyzes whether the claims arose from the same transaction or series of transactions as claims previously brought in Rhoades v. Savannah River Nuclear Solutions, LLC. The court overrules Plaintiff’s objections to the Magistrate Judge’s Report and Recommendation and concludes that the res judicata issue may be resolved on the pleadings and judicially noticed materials.

Holdings

1. Res judicata barred Plaintiff's Title VII claims because the prior Rhoades action involved a final judgment on the merits, the same parties or their privies, and claims arising from the same transaction or series of transactions.
2. Plaintiff could have brought his Title VII claims in Rhoades because the alleged religious-accommodation denial and adverse employment actions occurred before the Rhoades action was dismissed, and the claims could have been added as a convenient trial unit.
3. The court could resolve the res judicata defense on the pleadings without discovery or conversion to summary judgment because the defense clearly appeared on the face of the Complaint and undisputed facts from Rhoades could be judicially noticed.

Questions Presented

1. Whether res judicata barred Plaintiff's Title VII religious-discrimination claims because they arose from the same transaction or series of transactions as the prior Rhoades action challenging Defendant's COVID-19 vaccine mandate.
2. Whether Plaintiff could have brought his Title VII claims in Rhoades despite the EEOC charge and right-to-sue-letter timing.
3. Whether the res judicata defense could be resolved on a Rule 12(b)(6) motion without discovery or conversion to a Rule 56 motion.
4. Whether equitable considerations or a purported choice between injunctive relief and Title VII remedies prevented application of res judicata.

Disposition

dismissed