## Facts

- In 1979, multiple asbestos-exposed workers sued Johns-Manville Corporation, Owens-Corning Fiberglas Corp., and other asbestos manufacturers in Pennsylvania state court for personal injuries allegedly caused by defendants’ asbestos-related misconduct and negligence.
- The state-court complaint alleged asbestos-related injuries and diseases affecting plaintiffs’ lungs and other organs, including asbestosis, respiratory disorders, and the risk of mesothelioma and other cancers.
- In January 1981, defendants filed summary-judgment motions in the state-court action arguing the claims were barred by Pennsylvania’s statute of limitations.
- Rather than oppose the state summary-judgment motions, plaintiffs filed a new action in the U.S. District Court for the Eastern District of Pennsylvania against the same defendants, based on the same asbestos exposure.
- The federal complaint repeated the general injury allegations and added a more specific cancer allegation: adenocarcinoma of the transverse colon.
- Plaintiffs argued the federal case fell within admiralty jurisdiction and therefore should be governed by laches rather than a statute of limitations.
- On May 21, 1981, the Pennsylvania state court entered judgment for defendants in the state action on statute-of-limitations grounds.
- After the state judgment, defendants (including Owens-Corning) moved for summary judgment in federal court, arguing the federal action was barred by res judicata (claim preclusion).

## Issues

1. Whether a final Pennsylvania state-court judgment dismissing an asbestos personal-injury action as time-barred precludes a later federal action between the same parties arising from the same asbestos exposure.
2. Whether plaintiffs can avoid claim preclusion by pleading admiralty jurisdiction in federal court and arguing laches applies instead of the statute of limitations.
3. Whether alleging a specific diagnosis (adenocarcinoma of the transverse colon) in the later federal action states a different claim when the earlier state complaint alleged broad asbestos-related injuries and cancer risks.

## Decision

- The court granted summary judgment for defendants and dismissed the federal action as barred by res judicata (claim preclusion).
- The court treated the Pennsylvania state-court limitations judgment as a final judgment with claim-preclusive effect.
- Applying a transactional approach to “same cause of action,” the court held both suits arose from the same operative facts: plaintiffs’ asbestos exposure and resulting injuries.
- The court rejected the argument that admiralty jurisdiction and laches permitted plaintiffs to relitigate claims already reduced to final judgment in state court.
- The court held the federal colon-cancer allegation did not create a separate claim; it was a more specific statement of harm tied to the same exposure and the same general injury allegations raised earlier.

## Legal Principles

- Under 28 U.S.C. § 1738, federal courts generally must give state-court judgments the same preclusive effect they would receive in the courts of that state.
- Claim preclusion bars later litigation when there is (1) a final judgment, (2) the same parties (or their privies), and (3) a later suit based on the same claim.
- A “same claim” analysis may follow a transactional test (as reflected in Restatement (Second) of Judgments § 24): a plaintiff must seek all remedies arising from the same transaction or series of connected transactions in one action.
- A final dismissal on statute-of-limitations grounds can operate as a judgment that ends the plaintiff’s ability to relitigate the same claim against the same defendants.
- A plaintiff may not avoid claim preclusion by changing the forum, switching legal theories, or reframing jurisdiction (including labeling the later case as admiralty and invoking laches) when the later suit rests on the same exposure and injury allegations.
- Adding a newly specified injury diagnosis does not avoid claim preclusion when the earlier action already alleged broad organ damage and cancer risk tied to the same asbestos exposure.

## Conclusion

The court held that the workers’ federal asbestos personal-injury suit—though styled in admiralty and later specifying transverse-colon adenocarcinoma—was barred by claim preclusion because a final Pennsylvania state-court judgment had already dismissed the same exposure-based claims as time-barred.


Carbonaro v. Johns-Manville Corp., 526 F. Supp. 260 (1981)