U.S. Court of Appeals for the Second Circuit
Collateral Estoppel — Materially New Factual Allegations
Proctor v. LeClaire
Judges Kearse, Katzmann and Lohier
Background: The plaintiff prisoner had been administratively confined in a Special Housing Unit subject to reviews every 60 days. He appealed from a judgment dismissing his complaint that argued his due process rights had been violated as the decision to continue his confinement was based on evidence that should have been expunged from his record. In dismissing his suit, the court found that the action was barred by res judicata and collateral estoppel.
Ruling: The Second Circuit vacated the judgment. The court found that the plaintiff’s complaint alleged new facts and asserted a new cause of action.
Beth A. Williams for the plaintiff-appellant; Martin A. Hotvet, assistant solicitor general, for the defendant-appellee