Stutsman v. Kaiser Foundation Health Plan of Mid-Atlantic States, Inc.

How courts have described this case

Verbatim parenthetical descriptions written by other courts when citing this decision. Ranked by citation-network relevance.

• explaining that D.C. “has little, if any, interest in the marital relationship” of out-of-District residents
• observing that, for purposes of res judicata, whether a litigant brings a “second action under a different [legal] theory . . . is irrelevant”; res judicata hinges on whether the “factual nucleus” of the subsequent claim is the same, “not the theory upon which a plaintiff relies”
• “It is the factual nucleus, not the theory upon which a plaintiff relies, which operates to constitute the cause of action for claim preclusion purposes.”
• “This jurisdiction has long recognized that the tort of loss of consortium is a distinct cause of action for injury to the marriage itself ....”
• “[I]f, to the detriment of one of its own residents, Maryland would not assert its interest and disregard the [foreign] damage limitation, the District of Columbia courts should not do so.”
• “Virginia ... has abrogated this common law right of action and does not permit a husband to recover damages from a third party for loss of consortium due to injuries negligently inflicted upon his wife”

Source: CourtListener parenthetical corpus (CC0).