Snell v. Gustafson

Summary

The United States District Court for the Western District of Virginia denies Marcia Snell’s motion to alter or amend an interlocutory order and grants defendants’ renewed motion for summary judgment. The court holds that Virginia law governs the finality of the prior judgment for res judicata purposes and concludes that defendants did not waive their preclusion defenses by seeking to amend their pleadings after remand. It further finds privity and mutuality among the property owner, property manager, and leasing agent, making the prior jury verdict in favor of the owner preclusive of Snell’s constructive fraud claim.

Holdings

1. Virginia law governs all elements of res judicata, including the timing of when a judgment becomes final, under Semtek Int'l Inc. v. Lockheed Martin Corp.
2. Defendants did not waive their preclusion defenses; the three-month-and-ten-day delay was not unduly prejudicial and is distinguishable from the 480-day delay in Georgia Pacific.
3. Res judicata (both claim preclusion and issue preclusion) bars Snell's constructive fraud claim against Gustafson and Hasbrouck because they were in privity with Reid, mutuality exists, and the same cause of action arising from the same conduct was already adjudicated.

Questions Presented

1. Whether federal or Virginia law governs the timing of when a judgment becomes final for res judicata purposes
2. Whether Defendants waived their preclusion defenses by not raising them at the first reasonable opportunity
3. Whether res judicata (claim preclusion and issue preclusion) bars Snell's constructive fraud claim against Gustafson and Hasbrouck based on the prior jury verdict in favor of Reid

Disposition

affirmed