Duckett v. Fuller

Plaintiff filed suit against employees of SCDC and others, alleging that the food served to him at a prison managed by the SCDC was so deficient as to violate his Eighth Amendment rights. The district court dismissed the complaint under Rule 12(b)(6), concluding that plaintiff's claim is barred by the doctrine of res judicata because it is the same as a complaint filed against SCDC employees by a fellow inmate in 2010, which the district court dismissed on the merits. The court concluded that, because plaintiff was a nonparty to the earlier suit, he is not precluded from pursuing the same claims on his own behalf in the instant action unless the state defendants are able to demonstrate that at least one of the six exceptions to the general rule against nonparty preclusion applies pursuant to Taylor v. Sturgell. Because the state defendants have not demonstrated that any of the exceptions apply, the court reversed and remanded for further proceedings. View "Duckett v. Fuller" on Justia Law