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Geelan v. Mark Travel12/13/2005
Appellant appeals the state district court's dismissal of his claims against respondent for lack of subject-matter jurisdiction. Because we find that appellant's claims are preempted by the Railway Labor Act, we affirm.
FACTS
Appellant Steven Geelan worked as a union pilot for Sun Country Airlines, Inc. A collective-bargaining agreement (CBA) governed the terms of Geelan's employment. In December 2001, Sun Country laid off hundreds of its employees, including Geelan. Sun Country did not pay any accrued vacation or severance to Geelan. In January 2002, an involuntary bankruptcy proceeding was commenced against Sun Country, and a bankruptcy trustee began liquidating the company.
Geelan, along with a nonunionized coplaintiff who is not a party to this appeal, filed a complaint in state district court, alleging causes of action of "alter ego," "creditor control - principal and agent," and tortious interference with contract, seeking damages for accrued vacation pay and severance pay. Geelan named Mark Travel, Inc., a Wisconsin-based company, as the sole defendant, contending that it exercised extensive control over Sun Country. The state district court ruled that the Railway Labor Act preempted Geelan's claims and dismissed them for lack of subject-matter jurisdiction, but the nonunion coplaintiff's claims remained before the court. Minn. R. Civ. P. 54.02; Buchman Plumbing Co. v. Regents of Univ. of Minn., 293 Minn. 437, 439, 196 N.W.2d 629, 630 (1972).
Geelan then commenced a class-action lawsuit in federal district court in Minnesota, realleging the three causes of action that were in his state court complaint and adding two others: a wage claim under Minn. Stat. § 181.13 (2004) and a claim that Mark Travel failed to timely warn Geelan of his layoff under 29 U.S.C. § 2102 (2000). The state district court granted Mark Travel's motion to stay the state court proceedings pending the outcome of the federal district court action. The federal district court subsequently dismissed Geelan's four state-law claims on jurisdictional grounds. Geelan v. Mark Travel, Inc., 319 F. Supp. 2d 950, 953-55 (D. Minn. 2004).
On Geelan's motion, the state district court vacated its earlier order staying the state court proceedings and directed that judgment be entered on Geelan's claims. Geelan now appeals from the state district court's dismissal for lack of subject-matter jurisdiction of Geelan's claims of "alter ego" and "creditor control - principal and agent."
DECISION
I.
Mark Travel argues that the federal district court's decision bars Geelan's appeal on collateral-estoppel grounds. The federal court ruled that it lacked jurisdiction over Geelan's alter-ego and creditor-control claims because of the Rooker-Feldman doctrine. Geelan, 319 F. Supp. 2d at 953. The federal court also stated that "even without the Rooker-Feldman bar would lack jurisdiction" because Geelan failed to exhaust the remedies mandated by the CBA. Id. at 954.
Collateral estoppel, also known as issue preclusion, prevents a party from relitigating an issue that was determined in a prior action. Nelson v. Am. Family Ins. Group, 651 N.W.2d 499, 511 (Minn. 2002). Collateral estoppel applies when (1) the issue is identical with one in a prior adjudication; (2) there is a prior final judgment on the merits; (3) the estopped party was a party in the prior adjudication; and (4) the estopped party received a "full and fair opportunity to be heard on the adjudicated issue." Willems v. Comm'r of Pub. Safety, 333 N.W.2d 619, 621 (Minn. 1983) (quotation omitted). The application of collateral estoppel is a mixed question of law and fact, subject t
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