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A plaintiff who disputed his student loan obligations due to the defense of infancy, was precluded from bringing a second action regarding the same claim when his first action failed

The court held that the Court of Claims did not err by granting the defendant-university's motion for summary disposition on the basis that the plaintiff's claims were barred by res judicata. The court noted that plaintiff's state claims were "a mere repackaging of" his federal claims. "Although plaintiff's current claims view his challenge of the contract through a negligence framework, the essential ingredient in every one of plaintiff's claims is that he was unable to contract due to his infancy at the time he signed the promissory note for the purposes of his federal educational loan. It is not dispositive that plaintiff argued in federal court that the contract was voidable due to infancy and in state court argued that the infancy precludes a finding of mutual assent to form a valid contract, because, as the Court of Claims concluded, the operative facts giving rise to all of plaintiff's claims occurred in the spring of 2004 when he signed the loan documents." Further, to the extent that his claims differed "in any meaningful way, [he] has 'offered no justification for' his failure to bring the claims in the prior action." The Court of Claims "correctly concluded that plaintiff's knowledge of the present claims is irrelevant in determining whether he could have brought his claims in the prior action." Finally, the court found that "the federal court did assume jurisdiction over plaintiff's state-law claims, which it justified by considering judicial efficiency and the fact that plaintiff's state-law claims would fail because" the HEA "preempts state-law infancy defenses." Thus, it was "unnecessary to consider whether the federal court would have exercised supplemental jurisdiction over plaintiff's current state-law claims." Further, the current claims were properly considered the same as the state-law claims asserted in the federal action for the purposes of res judicata, "and thus, because the federal district court has already adjudicated those claims on their merits, it would be counter to the fundamental principle" of res judicatato allow him to "relitigate claims actually litigated in a prior suit." Affirmed.


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