3rd Circuit Clarifies 'Morgan's Rule' in Reinstating Second Complaint Barred by Res Judicata
“The sheriff’s sale occurred more than eight months after Harmon filed her first complaint, and therefore the first action does not bar her claims challenging the sheriff’s sale,” stated the per curiam opinion. “The District Court reasoned that Harmon could have amended her complaint in the first action to include these later-arising claims, but Morgan chose its bright-line rule in part to avoid ‘disputes about whether plaintiffs could have amended their initial complaints to assert claims based on later-occurring incidents.'”
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