The Supreme Court of Alabama ruled on December 19, 2008 that res judicata was established in a prisoner’s First Amendment case that was previously adjudicated by a Louisiana court of competent jurisdiction.

On October 3, 2006, Carl Braxton Toole, an Alabama state prisoner housed in a private prison in Louisiana operated by LCS, Inc., filed a 42 U.S.C. § 1983 action in district court in Evangeline, Louisiana. He claimed that he was denied his First Amendment right of access to the courts due to a lack of proper access to the law library. The district court entered summary judgment against Toole.

On October 11, 2007, Toole, now housed in Alabama, filed essentially the same action in the Montgomery Circuit Court. LCS filed a motion to dismiss the Alabama action based on res judicata and collateral estoppel. The motion was denied by the trial court. LCS then filed a petition for writ of mandamus in the state supreme court.

The Alabama supreme court issued the writ directing the Montgomery Circuit Court to dismiss the claims against LCS on the basis of res judicata. The supreme court found that the four elements necessary to establish res judicata were clearly present in this case: (1) a prior judgment on the merits, (2) rendered by a court of competent jurisdiction, (3) with substantial identity of the parties, and (4) with the same cause of action presented in both actions. See: Ex parte LCS, Inc., 12 So.3d 55 (Ala. 2008).

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