In April, the Honorable Charles Norgle of U.S. District Court for the Northern District of Illinois dismissed “a frivolous lawsuit brought purely for the purpose of causing an annoyance” against UMG Recordings, Inc. and Kanye West. Hijrahannah v. Def Jam Recordings, et al., Case No. 15-CV-11830 (slip op. April 11, 2017). The case presents a colorful and illustrative application of the doctrine of res judicata under federal law.
Plaintiff Haasan Hijrahannah originally filed suit against Def Jam Records in 2014, alleging that between 2004 and 2013 he provided sheet music to various artists who used his work without his permission. Hijrahannah v. Def Jam Recordings, Case No. 14-CV-872, 2014 WL 3586055, at *1 (N.D. Ill. July 14, 2014). The District Court dismissed the 2014 case for failure to state a claim under federal law. Id. The Seventh Circuit affirmed, and Plaintiff’s petition for rehearing en banc was denied. Hijrahannah v. UMG Recordings, Inc., 588 Fed. App x 507, 508 (7th Cir. 2015), reh g denied, Feb. 11, 2015.
Plaintiff subsequently filed the present case, in which he purported to add new defendants including Kanye West. Notably, Plaintiff alleged the same underlying facts and repeatedly referenced the 2014 case in his new complaint. The District Court dismissed the case with prejudice on the basis of res judicata, which prohibits parties from re-litigating issues that were or could have been raised in a previous action in which there was a final judgment on the merits. Res judicata applies where there is (1) an identity of the parties or their privies; (2) an identity of the cause of action; and (3) a final judgment on the merits in the earlier action. Slip Op. at 1,2 (citing Johnson v. Cypress Hill, 641 F.3d 867, 874 (7th Cir. 2011)).
In dismissing the complaint, Judge Norgle first explained that the parties to the instant litigation were essentially the same as the parties to the 2014 lawsuit, and that “[p]laintiff’s listing of redundant business divisions” did not affect their consistent identities. Id. at 2. Also, while Kanye West was a newly named defendant (apparently best known to the Court as the spouse of celebrity Kim Kardashian) Plaintiff never served him. Next, the cause of action was essentially the same as before: Plaintiff had sent unsolicited sheet music and notebooks with lyrics to the Defendants, and Plaintiff alleged that the Defendants used them without Plaintiff’s permission. Like the 2014 case, where Plaintiff alleged violations of federal and state laws, the present case included “a number of incoherent references to legal jurisprudence” but also alleged violations of his constitutional rights. Referring to Cypress Hill, the Court held “[i]f Plaintiff wanted to accuse Defendant of violating his constitutional rights, he had to do it in the previous case.” Id. at 2. As the 2014 case had reached a final judgment, res judicata barred Plaintiff’s second suit.
The Court dropped the proverbial mic on Plaintiff’s case when it stated that the doctrine of res judicata “encourages reliance on judicial decisions, bars vexatious litigation, and frees the courts to resolve other disputes.” Id. Because the case was already adjudicated, res judicata barred this vexatious litigation in its entirety. Id. (citing Brown v. Felsen, 442 U.S. 127, 131 (1979)).