Small Claims Case Bars Injured Worker’s Later Claims Against Employer – Employment Law Weekly

Small Claims Case Bars Injured Worker’s Later Claims Against Employer

July 22, 2019, Haoxiao Liu, a Goldengate bus driver trainee, was on a multi-hour bus trip with a Goldengate driving trainer. He sustained a host of injuries on this bus trip,

On December 26, 2019, Liu filed an action against Goldengate in small claims court, seeking compensation for injuries sustained on July 22, 2019. Following trial, plaintiff obtained a judgment against Goldengate in the amount of $615.

On July 19, 2021, Liu filed the instant lawsuit against Goldengate Bus Inc., and Gang Guo alleging claims for negligence and intentional tort arising out of the injuries sustained on July 22, 2019.

In his negligence cause of action, plaintiff alleges that defendants “failed to provide [him with] the necessary work environment,” “failed to protect [their] employee,” “failed to do anything to care and protect [their] new employee,” “failed to pay wage that [they] promised to pay,” and “failed to report the injury of the plaintiff to its insurance company.”

In his intentional tort claim, plaintiff similarly alleges that “[a]s a direct result of defendants’ [negligence], abuse of power, [and] hostile work environment,” he suffered injuries.

In response, defendants demurred, arguing that plaintiff’s claims were barred by the exclusive remedy rule and the doctrines of res judicata and/or collateral estoppel.

The trial court sustained defendants’ demurrer without leave to amend. It found that defendants “established that the workers’ compensation exclusivity rule bars Plaintiff’s claims” and that plaintiff’s claims against Goldengate were barred by the doctrine of res judicata.

The Court of Appeal affirmed the dismissal in the unpublished case of Liu v. Goldengate Bus -B320846 (July 2024).

Res judicata describes the preclusive effect of a final judgment on the merits. Res judicata, or claim preclusion, prevents relitigation of the same cause of action in a second suit between the same parties or parties in privity with them. Under the doctrine of res judicata a judgment for the defendant serves as a bar to further litigation of the same cause of action.

Claim preclusion applies when (1) the claim raised in the prior adjudication is identical to the claim presented in the later action; (2) the prior proceeding resulted in a final judgment on the merits; and (3) the party against whom the doctrine is being asserted was a party or in privity with a party to the prior adjudication.

“Here, all elements of res judicata are met. There is a final judgment in favor of plaintiff and against Goldengate arising out of the small claims court action. The claims raised therein are the same as those alleged in this action and involve the same parties. And, there was an adjudication on the merits, namely a trial.”

“Even though Guo was not a party to the small claims court action, the doctrine of res judicata bars plaintiff’s claims against him. As alleged in the complaint, his liability, if any, is entirely derived from Goldengate’s liability.”

Small Claims Case Bars Injured Worker’s Later Claims Against Employer

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