Armstrong v. Archuleta
Armstrong v. Archuleta
Opinion of the Court
MEMORANDUM OPINION
Six former federal criminal investigators and Gulf War veterans sue Katherine Ar-chuleta,
But what the parties have failed to mention is that this case already has been litigated in the U.S. District Court for the District of Columbia, see Adams v. Bowsher, 946 F.Supp. 37 (D.D.C. 1996), and the U.S. Court of Appeals for the D.C. Circuit, see Adams v. Hinchman, 154 F.3d 420 (D.C.Cir. 1998). Indeed, those cases recounted the same legislative history and challenged GAO’s refusal to apply a six-year statute of limitations under the Barring Act, 31 U.S.C. § 3702(b)(1)(A). Hinchman, 154 F.3d at 421-25. Because Plaintiffs had an opportunity to litigate GAO’s authority and their entitlement to a five-year statute of limitations, this action is barred. Hence, the Court will grant Defendants’ motion to dismiss under Federal Rule of Civil Procedure 12(b)(6) and deny Plaintiffs’ cross-motion for summary judgment.
The doctrine of res judicata, or claim preclusion, bars the court from hearing “repetitious suits involving the same cause of action once a court of competent jurisdiction has entered a final judgment on the merits.” United States v. Tohono O’Odham Nation, 563 U.S. 307, 131 S.Ct. 1723, 1730, 179 L.Ed.2d 723 (2011) (citation and internal quotation marks omitted). The doctrine bars a subsequent lawsuit if there has been prior litigation (1) involving the same claims or cause of action, (2) between the same parties or their privies, and (3) there has been a final, valid judgment on the merits, (4) by a court of competent jurisdiction. Smalls v. United States, 471 F.3d 186, 192 (D.C.Cir. 2006). Res judicata prevents the relitigation of claims that were actually litigated in a prior suit and those that could have been litigated but were not. Allen v. McCurry, 449 U.S. 90, 94, 101 S.Ct. 411, 66 L.Ed.2d 308 (1980); Drake v. FAA, 291 F.3d 59, 66 (D.C.Cir. 2002) (Res judicata bars the relitigation of “Issues that were or could have been raised in [the prior] action’ ”) (quoting Allen, 449 U.S. at 94, 101 S.Ct. 411); I.A.M. Nat’l Pension Fund v. Indus. Gear Mfg. Co., 723 F.2d 944, 949 (D.C.Cir. 1983) (noting that res judicata “forecloses all that which might have been litigated previously”). Thus, it relieves parties of the cost and vexation of multiple lawsuits, conserves judicial resources, prevents inconsistent decisions, and encourages reliance on adjudication. Montana v. United States, 440 U.S. 147, 153-54, 99 S.Ct. 970, 59 L.Ed.2d 210 (1979).
II. ANALYSIS
Plaintiffs were litigants in the Adams cases and therefore were parties to the prior action against GAO and OPM.
III. CONCLUSION
For the foregoing reasons, the Court will grant Defendants’ Motion to Dismiss [Dkt. 14], deny Plaintiffs’ Motion for Summary Judgment [Dkt. 19], and dismiss this action as barred under the doctrine of res judicata. A memorializing Order accompanies this Opinion.
. Katherine Archuleta was sworn in as Director of the Office of Personnel Management in November 2013; she is automatically substituted for former Director John Berry. See Fed. R. Civ. P. 25(d).
. In the prior action, Defendants were OPM; GAO; the Comptroller General; Bureau of Alcohol, Tobacco, Firearms and Explosives (ATF); Assistant Director of ATF; Drug Enforcement Administration (DEA); Deputy Assistant Administrator of DEA; Internal Revenue Service (IRS); National Director of Personnel for IRS; U.S. Customs Service; Assistant Chief Counsel of the U.S. Customs Service; U.S. Secret Service; Chief of the Personnel Division of the U.S, Secret Service; Department of Justice; and Department of Treasury. See Adams v. Bowsher, No. 95-2015 (D.D.C. filed Oct. 27, 1995).
. All Plaintiffs in this action received identical letters from OPM, which included the same reference to the Adams litigation. See Compl., Ex. 2 (Baldwin Final OPM Decision) [Dkt. 1-2] at 4; id. Ex. 3 (Dillow Final OPM Decision) [Dkt. 1-3] at 4; id. Ex. 4 (Gellick Final OPM Decision) [Dkt. 1-4] at 4; id. Ex. 5 (Grundberg Final OPM Decision) [Dkt. 1-5] at 4; id. Ex. 6 (Johnson Final OPM Decision) [Dkt, 1-6] at 4.
Reference
- Full Case Name
- George R. ARMSTRONG v. Katherine ARCHULETA, Director, Office of Personnel Management
- Status
- Published