## Facts

- Joseph L. Mathews previously filed a federal action against employees of the New York Racing Association, Inc. (NYRA).
- In that earlier suit, Mathews alleged that NYRA employees made libelous statements about him on many occasions, including statements connected to his disorderly conduct charge and his April 10, 1958 disorderly conduct trial.
- Mathews also alleged in the earlier suit that NYRA’s private investigators assaulted him at Jamaica Race Track on April 4, 1958.
- The court in the earlier federal action found against Mathews on all claims and entered judgment for the defendants.
- After that loss, Mathews brought the present federal action against NYRA and its private investigators.
- In the new complaint, Mathews again alleged that the investigators assaulted him at Jamaica Race Track on April 4, 1958.
- Mathews additionally alleged that the investigators kidnapped him, falsely arrested him, and falsely imprisoned him at the track on April 4, 1958.
- Mathews further alleged that defendants wrongfully charged him with disorderly conduct and maliciously prosecuted him, culminating in his conviction in the Magistrate’s Court of the City of New York on April 10, 1958.
- Defendants moved for summary judgment, arguing that the prior federal judgment barred the new suit under res judicata.

## Issues

1. Does the prior federal judgment for NYRA’s employees bar Mathews’s later suit against NYRA and its private investigators when both suits arise from the same April 4 and April 10, 1958 events, even though the later complaint adds additional tort theories?
2. Are NYRA and its private investigators sufficiently connected to the earlier employee-defendants (through agency or related relationships) to satisfy the “same parties or privies” requirement for claim preclusion?

## Decision

- The court granted defendants’ motion for summary judgment.
- The court held that the prior federal judgment on the merits precluded Mathews’s later action because the later claims arose out of the same events already litigated (the April 4, 1958 track incident and the April 10, 1958 disorderly conduct proceedings).
- The court rejected Mathews’s attempt to restyle the same controversy by adding labels such as kidnapping, false arrest, false imprisonment, and malicious prosecution when the underlying occurrences were the same as in the prior case.
- The court concluded that claim preclusion applied against NYRA and the private investigators because the new suit sought to impose liability based on the same conduct that had already been adjudicated in the earlier action involving NYRA-related personnel.
- The complaint was dismissed without a new trial on Mathews’s allegations.

## Legal Principles

- A final federal judgment on the merits bars a later action when the later suit arises from the same transaction or series of connected events and is brought against the same parties or those in privity with them.
- For claim-preclusion purposes, the identity of a “claim” turns on the underlying events giving rise to the dispute, not on the number of causes of action pleaded or the plaintiff’s choice of tort terminology.
- A plaintiff cannot avoid res judicata by bringing a second suit based on the same core facts after losing the first suit, even if the second complaint pleads additional legal theories or seeks different forms of relief.
- Privity may exist where the later defendants’ potential liability is tied to the same conduct previously litigated against related actors (including relationships involving agency and representation of the same interests in the earlier case).

## Conclusion

Because Mathews had already litigated—and lost—a prior federal case arising from the same April 4, 1958 Jamaica Race Track incident and the April 10, 1958 disorderly conduct proceedings, the court held that res judicata barred his later attempt to sue NYRA and its private investigators over the same events, and it granted summary judgment dismissing the action.


Mathews v. New York Racing Association, Inc., 193 F.Supp. 293 (1961)