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Civil Procedure Keyed to Hazard
Parsons Steel, Inc. v. First Alabama Bank
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Parsons Steel, Inc. (Plaintiff), a company owned by Jim and Melba Plaintiff, sued First Alabama Bank (Defendant) in Alabama state court. A state court suit, filed in February 1979, alleged that Defendant fraudulently induced Plaintiff to allow a third party to take control and eventually ownership of a subsidiary of Plaintiff. The subsidiary eventually went bankrupt in April 1979. In May 1979, Plaintiff sued Defendant in the United States District Court for the District of Alabama, alleging a violation of Defendant Holding Company Act. The federal case went to trial first, where the jury returned a verdict for Plaintiff. On a motion by Defendant, however, the judge entered a judgment notwithstanding the verdict for Defendant. After the conclusion of the federal case, Defendant raised the defense of res judicata in the state case, arguing that the state claims could have been raised in federal court and were thus precluded from being litigated in state court. The state court rejected this argument. The state case went to trial and the jury returned a verdict for Plaintiff in the amount of $4 million. Following the state court verdict, Defendant returned to federal court and sought an injunction against enforcement of the state verdict, arguing that res judicata prevented the entry of a verdict on the state counts. The district court agreed, holding that the state claims should have been raised with the federal claims in federal court. The district court enjoined Plaintiff from enforcing the verdict. Plaintiff appealed and the court of appeals affirmed the district court, holding that the injunction was appropriate under the “relitigation exception” to the Anti-Injunction Act. The court of appeals did not address the preclusive effect of the state court’s decision denying Defendant’s earlier res judicata argument. Plaintiff appealed.
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