Guerrero v. Cal. Dept. of Corrections and Rehabilitation
Victor Guerrero, a Mexican immigrant and aspiring California correctional officer, filed a federal action alleging discriminatory failure-to-hire against the California Department of Corrections and Rehabilitation (the CDCR), among other defendants. He pled federal and state law claims, but only his state claims allowed him to seek general damages.
The federal court dismissed Guerrero’s state claims on Eleventh Amendment grounds, effectively limiting his potential money recovery to the equitable remedy of backpay. To recoup damages, Guerrero filed this action in superior court. After final judgment was entered in the federal action—in Guerrero’s favor—the superior court dismissed his state claims under California claim preclusion principles.
On appeal, Guerrero now argues that federal law, not California law, governs the preclusive effect of the federal judgment. Under federal law, Guerrero contends, there is a well-recognized exception to claim preclusion rules where jurisdictional limitations in a prior suit blocked the plaintiff’s request for complete relief, as was the case here. We agree and shall reverse.