Porn v. National Grange Mutual Insurance Co.
United States Court of Appeals for the First Circuit
93 F.3d 31 (1996)
After successfully suing his insurer, National Grange (defendant), for breach of contract over unpaid underinsured-motorist coverage from a car accident, Daryl Porn (plaintiff) filed a second federal suit six months later against the same insurer, asserting bad-faith claims (breach of the covenant of good faith, emotional distress, and consumer-protection violations) arising from the same accident and denial of coverage. The district court granted National Grange summary judgment based on claim preclusion.
Whether, once final judgment on the merits is reached in an action, the plaintiff may bring subsequent claims against the defendant that arise out of the same transaction as the concluded suit.