CSI Worldwide, LLC v. Trumpf, Inc.

Dist. Ct. erred in dismissing on judicial estoppel grounds plaintiff’s action seeking $530,000 on theories of unjust enrichment and promissory estoppel, where plaintiff asserted that defendant had agreed to pay plaintiff directly for services that plaintiff rendered to third-party, whom defendant had hired to perform same services on behalf of defendant. While Dist. Ct. dismissed instant case because plaintiff had represented in third-party’s bankruptcy proceeding that third-party was sole debtor to plaintiff for claim in instant case, judicial estoppel did not apply, since plaintiff had not prevailed in bankruptcy proceeding by collecting instant debt from third-party’s estate in bankruptcy. Moreover, there is no authority to support Dist. Ct.’s belief that plaintiff’s claim as creditor in third-party’s bankruptcy’s proceeding necessarily abandoned all of plaintiff’s claims against other potentially responsible persons. Too, filing claim in bankruptcy proceeding did not foreclose related claims against non-bankrupt obligors.