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After dismissal of civil rights claim, arrestee could not pursue state law negligence claim

Kevin Dunn argued that he was injured by two Wayne County police officers during an arrest.  Dunn claimed that the officers used excessive force and filed a Federal civil rights action.  The Federal Court for the Eastern District of Michigan dismissed Dunn's claim, expressly finding that the officers acted reasonably during the arrest.  Dunn then filed a suit against the officers in Wayne County Circuit Court.  The trial judge and the Court of Appeals agreed that while Dunn's state law claims were technically different from the claims he had pursued in Federal Court, the factual finding of reasonableness by the officers collaterally estopped Dunn from maintaining them.  While the first (Federal) action was not res judicata because it was based on a different legal theory, in order to prove the independent state law claims Dunn would be required to establish a factual finding of "unreasonable" behavior that would be inconsistent with the prior court's holding. 
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