1403 (9th Cir. 1988); see also Clinton v. Acequia, Inc., 94 F.3d 568, 571 (9th Cir.1996) (stating that Ninth Circuit has consistently "found the artful pleading doctrine to support removal where a plaintiff flies his state law claims in state court in an attempt to circumvent the res judicata effect of a prior federal claim that has been reduced to judgment”). 36 . See e.g., Ultramar America Limited v. Dwelle, 900 F.2d 1412, 1415 (9th Cir.1990) (acknowledging that Sullivan recognized a new basis for invoking the artful pleading doctrine but noting that recharacterization of a state court claim under the res judicata branch of the doctrine may only occur when prior federal judgment resolved issues of federal not state law); Doe v. Allied-Signal, Inc., 985 F.2d 908, 912 (7th Cir. 1993) (<HOLDING>); Ethridge, 861 F.2d at 1403 (endorsing
recognizing this distinction recognizing distinction made by majority holding that the district courts finding of no discrimination was not clearly erroneous because the finding was supported by the record recognizing ultramar distinction but also finding that removal was improper because no res judicata was present recognizing the boggs distinction