In Simmons v. Trans Express, Inc., 19-438 (2d Cir. April 13, 2020), the U.S. Court of Appeals for the Second Circuit posed the following Certified Question to the New York Court of Appeals:
Under New York City Civil Court Act § 1808, what issue preclusion, claim preclusion, and/or res judicata effects, if any, does a small claims court’s prior judgment have on subsequent actions brought in other courts involving the same facts, issues, and/or parties? In particular, where a small claims court has rendered a judgment on a claim, does Section 1808 preclude a subsequent action involving a claim arising from the same transaction, occurrence, or employment relationship?
In this case, the plaintiff sued and obtained a judgment for unpaid wages in Queens County Supreme Court (which the employer paid and satisfied), and thereafter commenced this action in federal court. Citing New York Courts’ conflicting interpretations of Section 1808, the Second Circuit sought guidance from New York’s highest court to clarify the issue.