James Patterson sustained various personal injuries in a car accident while working for TRA Transportation. The accident occurred in Michigan, but compensation benefits were paid under the Alabama Workers' Compensation Act. A settlement of $60,000 was agreed upon in 2009. Before the settlement, Patterson had filed a civil action in Michigan against third parties responsible for his accidental injury, which was settled in 2010.
Avizent, the administrator of the employer's self-insured fund, aimed to intervene in the third-party action to enforce fund's reimbursement and subrogation rights under Alabama law. The motion was denied by the Michigan court. TRA Transportation filed a petition to reopen the settled case to enforce these rights against the settlement proceeds of the third-party action, which Alabama dismissed based on the doctrine of res judicata. TRA appealed this judgement, but Alabama upheld its decision, affirming that once a court makes a final determination, another court cannot adjudicate the same claim.