In Buck v. Thomas M. Cooley Law Sch., No. 09-1508, the Sixth Circuit faced a challenge to the district court's dismissal of plaintiff's lawsuit against her former law school under ADA and breach of various implied contracts, on the ground that the complaint was barred by res judicata.
As stated in the decision: "The allegations regarding defendant's treatment between 2002 and her second dismissal by the law school in 2006 are part of the same transaction - alleged misconduct and discriminatory animus by defendant towards her as a law student - as the allegations giving rise to her first lawsuit. Plaintiff alleged that defendant tried to deny her accommodations and otherwise interfered with her studies in her original complaint, her supplemental complaint, and her federal complaint."
Thus, in affirming the district court's dismissal of plaintiff's suit, the court held that she is precluded by res judicata from raising the claims in the present suit as she should have supplemented her complaint in state court with claims that arose during the pendency of that suit.