Williams v. Robinson – Case Brief
Williams v. Robinson, 1 F.R.D. 211 (D.D.C. 1940).
Facts: In an earlier lawsuit, Robinson’s (D) wife filed suit against him for maintenance. Robinson filed a counterclaim for divorce and alleged that his wife had committed adultery with Williams (P), and joined Williams as a co-respondent in his divorce claim. Williams denied all of the allegations.
P brought suit, claiming that he had been libeled and slandered by the allegations made by D in the divorce proceeding. D did not file an answer but moved for dismissal on the grounds that P had failed to assert the claim in his answer in the divorce proceeding. D asserted that P’s claim arose out of the same transaction or occurrence as the subject of the divorce proceeding and that the claim was therefore a compulsory counterclaim under FRCP 13(a) and could not be asserted in a separate proceeding. The trial court granted D’s motion to dismiss and P appealed.
Issue: What constitutes a “transaction or occurrence” under FRCP 13(a)?
Holding and Rule: A transaction or occurrence under Rule 13 (a) is whatever may be done by one person which affects another’s rights and out of which a cause of action may arise.
The court held that the defamatory language alleged by P constituted no portion of the facts or circumstances filed in D’s wife’s maintenance suit. There was no common point between the causes of action. To sustain D’s motion to dismiss would be in effect to require P to admit that there was a transaction or occurrence within the meaning of the rule, and as alleged by D in his cross complaint in the maintenance suit. P denied the acts of adultery.