## Facts

- Dr. Marvin P. Jones received National Health Service Corps (NHSC) scholarship funds totaling $33,543.50 to attend medical school (1980–1984) and later obtained a residency deferment.
- In 1987, Jones entered a “Private Practice Assignment Agreement” with the Department of Health and Human Services to work four years (July 8, 1987 to July 7, 1991) as a physician at Westside Urban Health Center in Savannah, Georgia, in exchange for cancellation of his NHSC obligation.
- The agreement contemplated reassignment if the placement ended early, unless termination was due to Jones’s failure to fulfill the entity’s employment requirements or the assignment requirements; if he failed to satisfy the service obligation, he could owe statutory repayment (including multipliers) with credit for partial service.
- Westside terminated Jones’s employment in June 1990, about one year before his service term ended.
- In a prior, separate lawsuit by Jones against Westside (Equal Pay Act/retaliatory discharge), a federal district judge issued an order finding Jones was fired for poor attendance and interpersonal difficulties.
- In a later reimbursement action, the United States sued Jones to recover scholarship funds and statutory amounts, asserting Jones failed to complete service and that reassignment was not required because his termination was for failure to meet employment requirements.
- The district court relied on the prior order’s factual findings and references to testimony as proof of the cause of termination and granted summary judgment to the United States.

## Issues

1. Whether the district court could rely on factual findings and testimony references contained in a prior federal court order from a different case as substantive evidence at summary judgment under judicial notice or a hearsay exception.
2. Whether, absent that prior order’s findings, genuine issues of material fact remained regarding the reason for Jones’s termination and whether the agreement required the government to reassign him.

## Decision

- The Eleventh Circuit vacated the summary judgment for the United States and remanded.
- The court held the district court improperly treated factual findings from another lawsuit as evidence to prove the truth of disputed facts in this case.
- Once the prior findings were excluded from substantive consideration, material factual disputes remained about why Jones was terminated and whether the reassignment clause applied, making summary judgment improper.

## Legal Principles

- A court may take judicial notice of the existence of another court’s order or judgment, but not of the truth of factual findings in that order when offered to prove disputed facts in a separate case.
- Another court’s findings of fact, offered for their truth in a different proceeding, are generally hearsay and are not admissible merely by labeling them “public records” or invoking judicial notice.
- Summary judgment is inappropriate when resolution depends on contested facts material to contractual duties, including whether a termination falls within an exception to a reassignment obligation.

## Conclusion

The Eleventh Circuit required reversal of summary judgment because the government’s proof depended on importing factual findings from prior litigation as substantive evidence, and the remaining record presented genuine disputes about the cause of termination and the government’s contractual duty to reassign.


United States v. Jones, 29 F.3d 1549 (11th Cir. 1994)