Watkins v. Resorts International Hotel and Casino, Inc.
Supreme Court of New Jersey
591 A.2d 592 (1991)
Watkins and her husband (plaintiffs) sued several Atlantic City casinos, including Resorts (defendant), in federal court alleging race discrimination against their bus company, but their federal claims were dismissed for lack of standing and for failure of proper service; they then refiled state-law claims against the same defendants in state court, which the defendants moved to dismiss based on res judicata, collateral estoppel, and the entire controversy doctrine arising from the earlier federal dismissal. The state trial and appellate courts dismissed the state suit, and Watkins sought further review.
Whether dismissals for insufficient service of process or lack of standing preclude relitigation of related claims in a later suit.