Res judicata "is not limited to only claims that were actually litigated." Merced v. Ponte, No. 17-CV-4918 (KAM), 2019 WL 1208791, at *9 (E.D.N.Y. Mar. 13, 2019), aff'd, 807 Fed.Appx. 127 (2d Cir. 2020). Rather, "it bars all legal claims that a party could have raised in the prior litigation."
Mireles v. Waco, 502 U.S. 9, 9 (1991) “Judicial immunity is conferred in order to [ensure] independent exercise of judicial authority without fear of facing suit in a personal capacity.” Merced v. Ponte, No. 17-CV-4918, 2019 WL 1208791, at *12 (E.D.N.Y. Mar. 13, 2019) (citing Bliven v. Hunt, 579 F.3d 204, 209 (2d Cir. 2009)); see also Bradley v. Fisher, 80 U.S. 335, 347 (1871) (“[I]t is a general principle of the highest importance to the proper administration of justice that a judicial officer, in exercising the authority vested in him, shall be free to act upon his own convictions, without apprehension of personal consequences to himself.”)
"The OATH pre-termination process provided [Quire] with notice of the charges [he] faced, the evidence underlying those charges and an opportunity to be heard at an administrative hearing where [his] counsel was able to present evidence on [his] behalf and challenge the evidence adduced against [him]." Merced v. Ponte, No. 17-CV-4918 (KAM), 2019 WL 1208791, at *10 (E.D.N.Y. Mar. 13, 2019), aff'd, 807 F. App'x 127 (2d Cir. 2020). "This sort of pre-termination process provided under New York law is certainly beyond 'minimal' and exceeds the 'very limited' constitutional requirement."
"Congress has specifically required all federal courts to give preclusive effect to state-court judgments whenever the courts of the State from which the judgments emerged would do so." Merced v. Ponte, No. 17-CV-4918 (KAM), 2019 WL 1208791, at *6 (E.D.N.Y. Mar. 13, 2019) (quoting Allen v. McCurry, 449 U.S. 90, 96 (1980)), aff'd, 807 F. App'x 127 (2d Cir. 2020); see also 28 U.S.C. § 1738 (requiring that judicial proceedings of any court in one state have "the same full faith and credit in every court within the United States").
It is well-settled that Article 78 proceedings constitute "an adjudication on the merits" for purposes of a res judicata analysis. Merced v. Ponte, 2019 WL 1208791, at *7 (E.D.N.Y. Mar. 13, 2019) (citing Bray v. New York Life Ins., 851 F.2d 60, 63-64 (2d Cir. 1988)). Moreover, Miller's constitutional claims seeking declaratory relief arise out of the "same transaction or series of transactions" as those at issue in his Article 78 proceeding and thus could have been raised in his Article 78 proceeding.