McConnell v. Travelers Indemnity Co.

Mr. and Mrs. Archie McConnell (plaintiffs), Louisiana residents injured in a car accident, sued Travelers Indemnity Co. (Travelers) (defendant) in federal court for personal injuries and medical expenses. Nearly two years later, Mr. McConnell separately sued in state court for his medical expenses. When Travelers moved for summary judgment arguing improper claim-splitting, Mr. McConnell voluntarily dismissed the state case with prejudice while the motion was pending, and the district court initially denied Travelers' motion. Travelers then argued that dismissing the state claim with prejudice effectively dismissed his entire underlying claim, since under Louisiana law the personal-injury claim could only have been pursued by amending the state case. The district court agreed and granted summary judgment for Travelers on res judicata grounds, and Mr. McConnell appealed.