Comer v. Murphy Oil USA, Inc.

On May 14, 2013, the Fifth Circuit affirmed on res judicata grounds the district court’s dismissal of plaintiffs’ claims. The Fifth Circuit rejected plaintiffs’ arguments that the district court’s 2007 judgment was not final or on the merits, noting that at no point in the appeals process for the 2007 judgment had the judgment been disturbed. The Fifth Circuit also refused plaintiffs’ request for an equitable exception to res judicata, invoking the “well-known rule that a federal court may not abrogate principles of res judicata out of equitable concerns.” The Fifth Circuit also held that the 2007 judgment was on the merits since res judicata principles applied to jurisdictional determinations.