Coen v. Cdc Software Corporation

Summary

The court held that the Court of Appeals applied an impermissibly broad understanding of res judicata by treating lawsuits as involving the same cause of action merely because they arose from the same employment termination. The prior contract action concerned CDC's failure to pay severance, while the later tort action concerned allegedly defamatory statements in an SEC filing, so res judicata did not bar the later suit. The court reversed and remanded for consideration of the alternative failure-to-state-a-claim ruling.