## Facts

- Car Carriers, Inc. and related motor-carrier plaintiffs hauled new Ford automobiles in the Chicago area from about 1968 to 1981 under regulated rate structures.
- Plaintiffs alleged Ford Motor Company and Nu-Car Carriers, Inc. engaged in a continuing scheme to injure plaintiffs’ hauling business and shift work to Nu-Car.
- Plaintiffs claimed Ford induced them to make significant capital investments (equipment and facilities) based on assurances of continued or increased hauling volume and higher compensation, but later did not provide the promised traffic or payments.
- Plaintiffs alleged Ford interfered with plaintiffs’ attempted mergers or acquisitions that could have strengthened their position.
- Plaintiffs alleged Ford solicited new bids for hauling work, enabling Nu-Car to submit an allegedly predatory bid that displaced plaintiffs.
- In 1982, plaintiffs filed a federal antitrust suit under § 1 of the Sherman Act; the district court dismissed the federal claim with prejudice, and the Seventh Circuit affirmed.
- In 1983, plaintiffs filed a new federal suit asserting RICO and Interstate Commerce Act claims, plus numerous Illinois law claims, based on the same business dispute.
- The district court dismissed the 1983 federal claims as barred by res judicata and dismissed the state claims without prejudice after declining pendent jurisdiction.

## Issues

1. Whether the prior federal judgment dismissing the 1982 antitrust action with prejudice precluded the 1983 federal RICO and Interstate Commerce Act claims.
2. Whether plaintiffs could avoid claim preclusion by recasting the same dispute under different federal statutes, adding factual detail discovered later, or pointing to jurisdictional limits affecting some state-law theories.
3. Whether the district court properly dismissed the state-law claims without prejudice after the federal claims were precluded.

## Decision

- The Seventh Circuit affirmed the dismissal of the 1983 action.
- The court held the 1983 federal claims were barred by res judicata because they arose from the same core set of operative facts as the 1982 antitrust claim.
- The court held plaintiffs could not split a single transactional dispute into successive federal suits by changing legal theories or adding further factual allegations.
- With no surviving federal claims, the district court properly declined pendent jurisdiction and dismissed the Illinois law claims without prejudice.

## Legal Principles

- Federal claim preclusion bars not only matters actually decided, but also claims that could have been brought in the earlier action.
- For res judicata, a “cause of action” is defined transactionally: all claims arising from a single core of operative facts must be litigated together or be lost.
- A change in legal theory (e.g., antitrust to RICO or regulatory claims) does not avoid preclusion when the underlying factual transaction is the same.
- Additional details learned later generally do not create a new cause of action if they relate to the same alleged course of conduct; parties are expected to investigate before filing.
- Jurisdictional arguments about state-law claims do not prevent preclusion of later-filed federal claims that could have been joined in the earlier federal case.

## Conclusion

The Seventh Circuit treated the later RICO and Interstate Commerce Act suit as an impermissible second attempt to litigate the same business dispute already resolved by a final federal judgment, and it affirmed dismissal of the federal claims on res judicata grounds while leaving state-law claims to be pursued, if at all, in a proper forum.


Car Carriers, Inc. v. Ford Motor Co., 789 F.2d 589 (7th Cir. 1986)