Saint-Fleur v. J.P. Morgan Chase Bank, N.A.
- Naomi Buchwald
- 1:24-cv-10036
- U.S. District Court · Southern District of New York
- 2
In Saint-Fleur v. J.P. Morgan Chase, Judge Buchwald dismissed the case with prejudice because an earlier action involving the same dispute had been dismissed for failure to prosecute.
Johanne Saint-Fleur and the defendant entities named in the case. The case was dismissed with prejudice, and the court directed the clerk to close it.
What happened
In Saint-Fleur v. J.P. Morgan Chase Bank, N.A., Johanne Saint-Fleur filed a complaint arising from the same events and seeking the same damages as an earlier case.
The earlier case had been dismissed for failure to prosecute, meaning the plaintiff did not move it forward. The court noted that this type of dismissal counts as a decision on the merits and that Saint-Fleur did not appeal it.
Judge Naomi Reice Buchwald ruled that the new case involved the same parties and facts, and dismissed the case with prejudice. The clerk was directed to end pending motions and close the case.
The detailed version
- Saint-Fleur v. J.P. Morgan Chase Bank, N.A. · No. 1:24-cv-10036
- Naomi Buchwald
- Mar. 20, 2025
Background
Johanne Saint-Fleur filed this case on December 31, 2024, against J.P. Morgan Chase Bank, N.A. and J.P. Morgan Chase & Co. The court stated that the complaint arose from the same events and sought the same damages as an earlier action involving Saint-Fleur and J.P. Morgan Chase Bank, N.A.
Earlier Case
The earlier action had been dismissed for failure to prosecute. Under Federal Rule of Civil Procedure 41(b), the court explained, a dismissal for that reason operates as an adjudication on the merits. The court also noted that Saint-Fleur did not appeal the earlier decision.
Ruling and Reasoning
The court found that the earlier complaint involved the same core facts and the same parties, or parties legally connected to them. It also found that nothing in the new complaint could not have been raised and litigated in the earlier action. Based on those findings, Judge Naomi Reice Buchwald ordered that this case be dismissed with prejudice. The clerk was directed to terminate any pending motions and close the case.
Read the full 2-page opinion on CourtListener, the free public archive maintained by the Free Law Project.