Diamond Williams v. Mastronardi Produce-USA, Inc. -Eastern District of Michigan at Detroit
Split Score
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Case Summary
Disposition
Reversed
The Sixth Circuit reversed the district court’s dismissal of Diamond Williams’s discrimination suit against Mastronardi Produce-USA. The panel held that, under Taylor v. Sturgell, a non-party subsidiary cannot invoke claim preclusion based merely on its “close and significant relationship” with the parent company previously sued; instead, one of Taylor’s six recognized exceptions must apply, and none did here.
Circuit Split Identified
Legal Issue
Whether, after Taylor v. Sturgell, federal courts may bind a non-party to a prior judgment under claim-preclusion based on a “close-and-significant-relationship” privity test, or must confine non-party claim preclusion to the six exceptions identified in Taylor.
Circuit Positions
Apply Taylor v. Sturgell exclusively—non-party claim preclusion is permitted only when one of the six traditional exceptions is satisfied; the close-and-significant-relationship test is impermissible.
Non-party claim preclusion may rest on a 'close and significant relationship' between the parties notwithstanding Taylor; Taylor is limited or distinguishable.
Conflict Summary
The Sixth Circuit rejects use of the broad 'close-and-significant-relationship' privity test and limits non-party claim preclusion to the six exceptions enumerated in Taylor. The First and Eighth Circuits have continued to apply the relationship-based privity approach, treating Taylor as limited or distinguishable and allowing preclusion where the new party had a close and significant relationship with a prior party.