Prenzler v. Director, Office of Workers' Compensation Programs

How later courts describe this case

• despite eight previous suicides, plaintiff showed mere negligence which does not establish a Sec. 1983 claim
• The effect on commerce “need only be minimal,” and a minimal effect may be established under a “depletion of assets theory.”
• despite eight previous suicides, plaintiff showed mere negligence which does not establish a § 1983 claim
• because the government allege new facts requiring additional relief, which were not available when the government sought and obtained injunctive in a prior action, the later action for further injunctive relief was not barred by the doctrine of res judicata merger or collateral estoppel