Coleman v. Blanchette
A prisoner's civil-rights suit, alleging that he was force fed with unnecessary brutality, can be barred by the doctrine of res judicata, if a state court previously held that the state possessed the right to force feed. The plaintiff prisoner, William Coleman, began a hunger strike and lost about 106 pounds, to protest his conviction of sexual assault in a spousal relationship. Dr. Edward Blanchette found that Coleman risked sudden death. When he weighed 129 pounds, Coleman asked to see a priest. Dr. Blanchette ordered forced intravenous hydration. A state court issued injunctions, to permit officials to force feed Coleman. Coleman refused to sip water when force fed, to ease the insertion of the tube, and claimed that he suffered excruciating pain. Coleman filed the present civil-rights suit, alleging the defendants violated his due-process rights under the U.S. and Connecticut constitutions and the Convention Against Torture. The defendants moved to dismiss on the basis of res judicata. Coleman objected that his civil-rights suit is fundamentally different than the earlier suit brought by the commissioner of the Department of Correction to obtain permission to force feed. Coleman claimed that he suffered pain when force fed and that the state court did not grant permission to force feed with unnecessary brutality. The doctrine of res judicata provides that a final judgment on the merits precludes the relitigation of issues that were or could have been raised in the earlier action. The District Court found Coleman was merely attempting to relitigate claims and issues previously decided in Connecticut state courts. An earlier state court action resulted in an adjudication on the merits. Coleman received a full and fair opportunity to argue against the request to force feed, as cruel and inhumane, pursuant to the U.S. Constitution and the Connecticut Constitution. State courts dismissed claims that conditions of confinement were abusive and constituted torture. The District Court wrote, "This court is bound by statute, 28 U.S.C. §1738, and the doctrines of res judicata and collateral estoppel to give full faith and credit to these rulings." The District Court granted the defendants' motion to dismiss.