## Facts

- Archie McConnell and his wife, Louisiana residents, were injured as passengers in an automobile accident involving a vehicle insured by Travelers Indemnity Company and Employers Casualty Company of Dallas.
- Under Louisiana community property law at the time, Mrs. McConnell’s personal-injury claim was separate property, while Mr. McConnell’s personal-injury claim and both spouses’ medical-expense claims were community property, enforceable by the husband as head and master of the community.
- Mrs. McConnell filed a Louisiana state-court tort action against the insurers for her personal injuries; Mr. McConnell joined only to recover medical expenses he paid for his wife’s treatment.
- About a week later, Mr. McConnell filed a separate federal action against the same insurers seeking damages for his own personal injuries and his own medical expenses from the same accident.
- While the federal case was pending, Mr. McConnell obtained a state-court dismissal “with prejudice” of his own state-court medical-expense claim.
- The federal district court ultimately granted summary judgment for the insurers, holding the federal action barred under Louisiana res judicata principles due to the state-court dismissal with prejudice.

## Issues

1. Under Louisiana law, were the community-property damage claims arising from the same automobile accident a single, indivisible cause of action that could not be split between state and federal suits?
2. Did Mr. McConnell’s state-court dismissal with prejudice of part of the community claim operate as a final judgment barring his remaining federal community claims by res judicata?

## Decision

- The Fifth Circuit affirmed the grant of summary judgment for the insurers.
- The court held that Louisiana law treated the community claims arising from the accident as a single cause of action that could not be divided among separate suits.
- The state-court dismissal with prejudice was treated as a final adjudication that extinguished the entire community cause of action and barred the later federal suit by res judicata.

## Legal Principles

- Under Louisiana procedural law, a plaintiff must assert in one action all claims arising from the same transaction or occurrence; a single cause of action may not be split into multiple suits seeking different items of damage.
- When Louisiana community-property rules place tort recovery for certain injuries and medical expenses in the community, the husband (as the then-recognized representative of the community) is the proper party to assert those community claims.
- A dismissal “with prejudice” constitutes a final judgment on the merits for res judicata purposes.
- If an indivisible cause of action is reduced to a final judgment between the same parties, res judicata bars subsequent litigation of the same cause of action even when the later suit seeks different elements of damage.

## Conclusion

The Fifth Circuit applied Louisiana’s anti-claim-splitting and res judicata rules to hold that Mr. McConnell’s dismissal with prejudice of a portion of the community claim in state court barred his separate federal action for the remaining community damages arising from the same accident.


McConnell v. Travelers Indem. Co., 346 F.2d 219 (5th Cir. 1965)