Position::Other Recent Decisions

Middleton v. United States Department of Labor

The U.S. District Court for the District of Columbia grants the motion by the defendant government agency to dismiss the plaintiff's claims of negligence and breach of fiduciary duties. The plaintiff is a former employee of a health care company and was a participant in the company retirement plan. The defendant is the Department of Labor (DOL). The plaintiff filed a complaint with DOL in June 2001 alleging that her former employer and the retirement benefits planning company mishandled her retirement account. The plaintiff then also asserts that DOL made verbal and written misrepresentations regarding her complaint and alleges negligence and breach of fiduciary duties by DOL in violation of the Employee Retirement Income Security Act of 1974 (ERISA). The plaintiff has filed or attempted to file at least 18 lawsuits related to this same cause of action. The defendant asserts that relief is barred by the doctrines of sovereign immunity and res judicata as well as statutes of limitations. Res judicata precludes further litigation of a cause of action if there has been prior litigation involving the same claims or cause of action between the same parties or their privies and there has been a final judgment on the merits by a court of competent jurisdiction. To determine whether the prior litigation involved the same claims or cause of action, a court looks at whether the actions share the same nucleus of facts. In this case, federal agencies are in privity with the U.S. government for purposes of res judicata, which means that a previous lawsuit against any federal...

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