Res judicata; PT Today, Inc. v. Commissioner of Office of Fin. & Ins. Servs.; Principle that recoupment decreases a plaintiff’s recovery by reducing any judgment in its favor by any claim the defendant may have to damages arising out of the same contract or transaction; McCoig Materials, LLC v. Galui Constr., Inc.; Subject-matter jurisdiction

The court held that the trial court did not err by granting summary disposition for defendant based on res judicata. Plaintiff sued defendant in circuit court claiming it failed to properly repair plaintiff’s bulldozer, resulting in damages for loss of use. Defendant sued plaintiff in district court for unpaid invoices, and plaintiff counterclaimed. The circuit court denied plaintiff’s motion to consolidate the suits. It later granted summary disposition for defendant based on res judicata, noting the doctrine “fit[] this situation like a glove.” On appeal, the court rejected plaintiff’s argument that its damages were not decided in the district court, and “could not have been, given the jurisdictional monetary limit applicable to district courts.” It noted that the “crux of plaintiff’s complaint in the circuit court, and the crux of the counterclaim in the district court, was defective workmanship.” The “district court largely rejected plaintiff’s argument about defective workmanship but decided to compensate plaintiff for $1,837 worth of repairs—thus ruling on the issue in question.” Further, it “had jurisdiction in that it could have granted recoupment for any amount due to plaintiff based on its counterclaim.” Moreover, it “could have granted damages for loss of months of use up to $25,000.” As such, the court declined to rule, “under the specific circumstances of this case, that res judicata cannot apply because the district court lacked subject-matter jurisdiction.” Affirmed.