Yohannes v. Minnesota IT Services

Background

Barnabas A. Yohannes, proceeding without a lawyer, sued Minnesota IT Services (MNIT) and Anne Sheridan in an employment-discrimination dispute. The opinion states that MNIT provides information-technology services to Minnesota state agencies and that Sheridan supervised Yohannes at relevant times.

Yohannes had previously sued MNIT in federal court over alleged discrimination based on race, national origin, and color, as well as alleged failure to hire or promote him, termination, unequal treatment, retaliation, and harassment. In that earlier case, the court dismissed some claims for failure to exhaust administrative remedies, dismissed the retaliation claim as untimely, and dismissed the race and national-origin claims for failure to state a claim. A magistrate judge later denied Yohannes’s motion to amend that complaint. Yohannes voluntarily dismissed the earlier lawsuit with prejudice, including claims that were or might have been alleged in it.

MNIT terminated Yohannes’s employment on August 9, 2022. In this case, filed in 2023, Yohannes alleged discrimination under Title VII, the Age Discrimination in Employment Act, and 42 U.S.C. § 1981, based on race, religion, national origin, color, and age. He also alleged that MNIT defamed and libeled him after terminating his employment. His amended complaint added Sheridan as a defendant and withdrew claims under several Minnesota statutes, including the Minnesota Human Rights Act, the Minnesota Fair Pay Act, and the Minnesota Whistleblower Act. He sought injunctive relief, reinstatement, and damages.

Res judicata and the federal claims

The defendants moved to dismiss based on res judicata and failure to state a claim. Res judicata is a rule that prevents a party from bringing a later case based on the same claims or the same connected series of events after a final judgment in an earlier case.

The court applied a transactional test, asking whether the claims arose from the same nucleus of operative facts. It concluded that much of Yohannes’s amended complaint repeated allegations from the earlier lawsuit. The court also treated his termination claim as a continuation of the alleged discrimination and retaliation at issue in the earlier case. Because the termination occurred while the earlier lawsuit was pending, the court held that Yohannes could have sought to add that claim in the earlier case instead of dismissing that case with prejudice.

The court therefore held that Yohannes’s federal discrimination and retaliation claims were barred by res judicata and must be dismissed. The court also dismissed the § 1981 claim because the amended complaint did not provide allegations supporting a claim that MNIT interfered with Yohannes’s right to contract because of his race. The court additionally stated that the § 1981 claim was barred by res judicata to the extent it relied on the discrimination allegations from the earlier lawsuit.

The court noted that Sheridan was not named in the earlier lawsuit but was in privity with MNIT as its employee. Accordingly, her addition as a defendant did not prevent application of res judicata.

Defamation and state-law jurisdiction

The court reached a different conclusion about the post-termination defamation and libel claim. It found that the alleged facts appeared to have occurred after Yohannes dismissed the earlier lawsuit and involved new, separate conduct by MNIT. The court was therefore not persuaded that this claim was barred by res judicata.

After dismissing all federal claims, however, the court declined to exercise supplemental jurisdiction over the remaining state-law claim. Supplemental jurisdiction allows a federal court to hear related state-law claims in the same case, but the court concluded that the relevant factors favored leaving the state-law issue to state courts. The court also noted that discovery had not begun and that it had not devoted substantial resources to the case.

Disposition

The court granted the defendants’ motion to dismiss. It dismissed the federal claims with prejudice, meaning the order barred those claims from being brought again in this case. It dismissed the defamation/libel claim without prejudice, with leave to file in state court. The order directed that judgment be entered accordingly.