New York Life Ins. v. Gillispie, 98-60654
| Decision Date | 22 February 2000 |
| Docket Number | No. 98-60654,98-60654 |
| Citation | 203 F.3d 384 |
| Parties | (5th Cir. 2000) NEW YORK LIFE INSURANCE COMPANY, Plaintiff-Appellant, v. SHEREE GILLISPIE, Defendant-Appellee |
| Court | U.S. Court of Appeals — Fifth Circuit |
[Copyrighted Material Omitted] Appeal from the United States District Court for the Northern District of Mississippi
Before GARWOOD, WIENER, and DENNIS, Circuit Judges.
In this insurance coverage dispute, Plaintiff-Appellant New York Life Insurance Company ("New York Life") asks us to reverse the district court's dismissal of its motion for a preliminary injunction enjoining on grounds of res judicata and collateral estoppel a lawsuit brought against it in state court by Defendant-Appellee Sheree Gillispie. The district court ruled that the issuance of such an injunction is prohibited by the Anti-Injunction Act, 28 U.S.C. 2283, which generally denies the federal courts the power to enjoin state court proceedings. New York Life contends that the district court erred in so ruling, arguing that the instant case falls within the relitigation exception to the Anti-Injunction Act. Agreeing with New York Life, we reverse and remand with instructions to the district court to enter the injunction.
Ronald Gillispie died in 1993. His wife, Sheree Gillispie, is the named beneficiary of a life insurance policy issued to Mr. Gillispie by New York Life Insurance Company. Shortly after Mr. Gillispie's death, Mrs. Gillispie submitted a claim to New York Life alleging entitlement to the proceeds of the policy. New York Life denied the claim, contending that Mr. Gillispie's death was the result of a suicide. Suicide is unambiguously excluded from coverage under the policy.
In 1995, Mrs. Gillispie filed a complaint against New York Life in the United States District Court for the Northern District of Mississippi, alleging breach of contract and bad faith denial of benefits. New York Life moved for summary judgment. Mrs. Gillispie's attorney did not respond to the motion. In early 1996, the court granted New York Life's motion for summary judgment, explicitly finding that "[a]ll evidence points to the decedent's death as a suicide."
Mrs. Gillispie subsequently hired new counsel to represent her. Her new attorney succeeded in convincing the Chancery Court of Tippah County, Mississippi to order the issuance of an amended death certificate declaring the cause of Mr. Gillispie's death to be accidental. In 1997, Mrs. Gillispie filed another complaint against New York Life, this time in the Circuit Court of Tippah County, Mississippi. The complaint stated the same basic causes of action as had the 1995 federal suit, alleging breach of contract and bad faith denial of benefits.
New York Life removed the suit to federal court, but it was subsequently remanded for lack of diversity jurisdiction. New York Life then brought the instant action in federal district court, seeking to enjoin the state court proceedings on grounds of res judicada and collateral estoppel. The district court dismissed New York Life's action with prejudice, finding that (1) it was barred by the Anti-Injunction Act and (2) the relitigation exception to the Anti-Injunction Act was inapplicable. This appeal followed.
We review the denial of a preliminary injunction for abuse of discretion.1 Conclusions of law made with respect to the denial of a preliminary injunction, however, are reviewed de novo.2 The only issue before the Court is the proper scope and application of the relitigation exception to the Anti-Injunction Act. Our review is therefore de novo.
Although the Anti-Injunction Act generally denies federal courts the power to "grant an injunction to stay proceedings in a State court,"3 it provides that a federal court may enjoin state court proceedings "to protect or effectuate its judgments."4 This exception 5 We apply a four-part test to determine whether the exception is applicable:
First, the parties in a later action must be identical to (or at least in privity with) the parties in a prior action. Second, the judgment in the prior action must have been rendered by a court of competent jurisdiction. Third, the prior action must have concluded with a final judgment on the merits. Fourth, the same claim or cause of action must be involved in both suits.6
The only issue before us today is whether Mrs. Gillispie's 1997 state suit presents "the same claim or cause of action" as did her 1995 federal suit.7
The parties have manifestly different views concerning the issues presented by Mrs. Gillispie's two lawsuits. New York Life contends that the two suits present the same issue: Whether Ronald Gillespie died as the result of a suicide or as the result of an accident. Mrs. Gillispie, on the other hand, contends that the first lawsuit merely determined whether New York Life had a contractual duty to pay based on then-available evidence, whereas the purpose of the second lawsuit is to have the courts determine whether New York Life has a contractual duty to pay based on now-available evidence, central to which is the amended death certificate.
The district court erred in adopting Mrs. Gillispie's view of the case. We use a transactional test to determine whether two claims involve the same cause of action, under which the critical question is "not the relief requested or the theory asserted but whether the plaintiff bases the two actions on the same nucleus of operative facts."8 In evaluating the res judicata effect of a...
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