United States Court of Appeals for the Eighth Circuit · 2019-07-25
42usc1981: author: Astra2 · not independently reviewed
Case and law context
Role: background; posture: Appeal from res judicata dismissal of §1981 suit after Missouri tort action on identical facts was dismissed with prejudice as a discovery sanction.; result: claimant-lost; claim:
Uncertainty
None recorded
Misfit
No preclusion defense id exists in 42usc1981.law. The claim is stored as background/procedural/not-reached under contractual-impairment with the exact preclusion holding, rather than mislabeling res judicata as limitations. There is no neutral/context fact polarity in v1.
B · Case × element grid
Top-level elements follow claim order in panels of up to six elements. Case rows repeat across panels. Every recorded block retains its holding and basis; multiple blocks are not merged into a case-level verdict. ✓ satisfied · ✗ not satisfied · ○ not reached · · not addressed. Muted blocks are not counted. Sub-element evidence remains on case and element pages.
Elements 1–6 of 15
| Case | Persons protected by equal contractual rights | Plaintiff has rights in an existing or proposed contract | Formation performance termination or contractual benefits | Judicial intentional-race-discrimination requirement | Judicial but-for causation of contractual injury | Nongovernmental impairment |
|---|---|---|---|---|---|---|
| Brown v. Kansas City Live, LLC — 931 F.3d 712 (2019) · United States Court of Appeals for the Eighth Circuit · 2019 (42usc1981: author: Astra2 · not independently reviewed) | · not addressed | · not addressed | ○ not reached · basis not recordedNot counted: background/procedural | · not addressed | · not addressed | · not addressed |
Elements 7–12 of 15
| Case | Judicial section 1983 remedial route for state-law impairment | Opposition to racial impairment of contract rights | Judicial defendant-knowledge requirement for retaliation | Judicial material-adversity requirement for retaliation | Judicial causation requirement for retaliatory injury | Contract and retaliation scope with noncontract clauses identified |
|---|---|---|---|---|---|---|
| Brown v. Kansas City Live, LLC — 931 F.3d 712 (2019) · United States Court of Appeals for the Eighth Circuit · 2019 (42usc1981: author: Astra2 · not independently reviewed) | · not addressed | · not addressed | · not addressed | · not addressed | · not addressed | · not addressed |
Elements 13–15 of 15
| Case | Judicial hostile-environment threshold and attribution | Claim-specific limitations and accrual | Compensatory equitable punitive and fee remedies |
|---|---|---|---|
| Brown v. Kansas City Live, LLC — 931 F.3d 712 (2019) · United States Court of Appeals for the Eighth Circuit · 2019 (42usc1981: author: Astra2 · not independently reviewed) | · not addressed | · not addressed | · not addressed |
Instances and excluded annotation blocks
| Case | Element | Holding and scope | Pattern | Exact source quotations |
|---|---|---|---|---|
| Brown v. Kansas City Live, LLC — 931 F.3d 712 (2019) · United States Court of Appeals for the Eighth Circuit · 2019 — not reached (42usc1981: author: Astra2 · not independently reviewed) | Formation performance termination or contractual benefits | not_reached Excluded from merits counts background / proceduralRestaurant purchase and racially charged removal are allegations underlying the later §1981 theory. The court decides claim preclusion only and never decides an impaired-contract element. | preclusion/same-incident-new-legal-theory | Brown's lawsuit stems from events that occurred at the Power and Light District in Kansas City, Missouri. After purchasing a few drinks at an outdoor bar, Brown sought to enter the bar's associated restaurant to use the bathroom. When he came out, three men told him he was trespassing and needed to leave. Brown alleges the men cursed at him, using racial slurs, and pushed Brown out of the restaurant. Brown then walked directly to two nearby police officers and stated he wanted to file a complaint. The officers detained Brown at a security guard office and eventually let him go, after giving him a ticket for trespassing.Source: docroot/ir/caselaw/f3d_931.jsonl#/f3d/931/0712-01; Unicode character offsets [166:793] (end exclusive); SHA-256 c59c3c91c80ae5470a000d7244dc23669eed20217af913659eccc3dcaadd603f.As the judgment was issued by a Missouri court, Missouri res judicata law applies. See Brown v. St. Louis Police Dept. , 691 F.2d 393, 395-96 (8th Cir. 1982) ; see also Laase, 638 F.3d at 856 ("[T]he law of the forum that rendered the first judgment controls the res judicata analysis."). Under Missouri law "res judicata applies where (1) 'the prior judgment was rendered by a court of competent jurisdiction, (2) the decision was the final judgment on the merits, and (3) the same cause of action and the same parties or their privies were involved in both cases.' " Bannum, Inc. v. City of St. Louis , 195 S.W.3d 541, 544 (Mo. Ct. App. 2006) (quoting Biermann v. United States , 67 F. Supp. 2d 1057, 1060 (E.D. Mo. 1999) ). Res judicata bars relitigation from the same "operative facts giving rise to one or more bases for suing" and applies "to every point properly belonging to the subject matter of litigation and which the parties, exercising reasonable diligence, might have brought forward at that time." Chesterfield Village, Inc. v. City of Chesterfield , 64 S.W.3d 315, 318 (Mo. 2002) (en banc) (quoting King Gen. Contractors, Inc. v. Reorganized Church of Jesus Christ of Latter Day Saints , 821 S.W.2d 495, 501 (Mo. 1991) (en banc)).Source: docroot/ir/caselaw/f3d_931.jsonl#/f3d/931/0712-01; Unicode character offsets [2910:4157] (end exclusive); SHA-256 c59c3c91c80ae5470a000d7244dc23669eed20217af913659eccc3dcaadd603f.Brown has asserted the same cause of action against the same party in federal court that he did in the state court, which had jurisdiction and entered a final judgment. Therefore, this suit is barred by res judicata.Source: docroot/ir/caselaw/f3d_931.jsonl#/f3d/931/0712-01; Unicode character offsets [6634:6850] (end exclusive); SHA-256 c59c3c91c80ae5470a000d7244dc23669eed20217af913659eccc3dcaadd603f. |