Grande

Grande v. Eisenhower Medical Center

Good Law
Supreme Court of CaliforniaJune 30, 2022S261247California6,229 words

Opinion

Opinion

Sakauye, J.

Opinion of the Court by Cantil-Sakauye, C. J.

A staffing agency (FlexCare LLC) arranged for a nurse (Lynn Grande) to work at a hospital (Eisenhower Medical Center). The nurse sued the staffing agency for violating the Labor Code and the Unfair Competition Law. The parties settled and the court entered judgment upon the settlement. The hospital was not a party to that initial lawsuit and the settlement did not name the hospital as a released party. The nurse then sued the hospital based on the same alleged violations. The hospital argued that, because of the first judgment, claim preclusion foreclosed the nurse’s second suit. The Court of Appeal disagreed, criticizing the reasoning of a published opinion that found claim preclusion on similar facts. (Grande v. Eisenhower Medical Center (2020) 44 Cal.App.5th 1147, 1162–1163 (Grande), criticizing Castillo v. Glenair, Inc. (2018) 23 Cal.App.5th 252, 278–281 (Castillo).) We granted review to resolve this tension in the case law. The core of this dispute concerns privity. Judgments bind not only parties, but also “those persons ‘in privity with’ parties.” (Armstrong v. Armstrong (1976) 15 Cal.3d 942, 951.) Questions about privity…

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