Also known as:claim preclusive effect · claim-preclusion effect · claim preclusion · res judicata effect
Written by attorneys · grounded in primary & secondary sources — see below
A final judgment's power to bar a party from asserting in a later action any claim that was or could have been raised in the prior proceeding between the same parties.
Sources & Authorities
How it applies
Common Examples
6
Limitations Dismissal Preclusion Dispute
Charles Cunningham sued Cascade Manufacturing in State A superior court for breach of a supply contract. The court dismissed the action with prejudice after finding the claim time-barred under State A's four-year statute of limitations, and State A law treats such dismissals as adjudications on the merits. Cunningham refiled the identical claim in federal court in State B, where precedent treats limitations dismissals as non-merits rulings. The federal court must determine whether the State A judgment carries claim-preclusive effect.
Diversity Judgment Preclusion Question
Carlos Castillo filed a diversity action against Cobalt Energy in federal court in State X alleging improper termination of a services agreement. After the court dismissed the suit on statute-of-limitations grounds, Castillo attempted to bring the same claim in State Y state court. The State Y court must decide whether the federal dismissal carries claim-preclusive effect under applicable preclusion rules.
Select any source to read its text and confirm it supports the definition.
Cases
Restatements
Casebooks
Hornbooks
Course Outlines
Study Supplements
Shady Grove Orthopedic Associates, P.A. v. Allstate Insurance Co.559 U.S. 393 (USSC 2010)
Retroactivity and Preclusion Issue
Connor Clark obtained a federal judgment against Cypress Technologies on a civil rights claim. Clark later attempted to assert the identical claim in a second federal action against the same defendant. The court must decide whether the prior federal judgment carries claim-preclusive effect barring the subsequent proceeding.
Teague v. Lane489 U.S. 288 (1989)
Merits Dismissal Preclusive Force
Catherine Carter sued Crystal Dynamics in federal court and obtained a final judgment dismissing her contract claim on the merits. Carter then attempted to assert a related claim arising from the same transaction in a second federal action. The court must decide whether the first judgment exerts claim-preclusive effect over the new claim.
Federated Dep’t Stores, Inc. v. Moitie452 U.S. 394, 399 n.3 (1981)
Injunction and Preclusion Scope
Curtis Cannon secured a federal judgment enjoining General Motors Corp. from enforcing a prior state judgment. Cannon later invoked that federal judgment to prevent relitigation of the underlying dispute in another forum. The court must determine the claim-preclusive effect of the federal injunction on the parties' subsequent claims.
Baker v. General Motors Corp.522 U.S. 222, 246 (1998)
Class Action Preclusion Question
Christopher Collins, a member of a plaintiff class in a State A action against Phillips Petroleum Co., later filed an individual suit in federal court asserting the same claims. Phillips Petroleum moved to dismiss, arguing the prior class judgment carries claim-preclusive effect. The federal court must resolve whether the class judgment bars Collins's individual action.
Phillips Petroleum Co. v. Shutts472 U.S. 797 (USSC 1985)
Common questions
Frequently Asked
4
Does Federal Rule of Civil Procedure 41(b) control whether a dismissal counts as on the merits for claim preclusion purposes?+
No. The rule addresses only the effect of a dismissal within the same federal proceeding and does not dictate preclusive consequences in later actions. Jurisdictions remain free to decide whether particular dismissals, such as those based on the statute of limitations, carry claim-preclusive effect.
When a state court dismisses a claim as time-barred and treats the dismissal as an adjudication on the merits, must a federal court give that judgment the same preclusive effect?+
Yes. Under the full faith and credit statute, a federal court must accord the state judgment the same claim-preclusive effect it would receive in the courts of the rendering state, regardless of how the federal court or the forum state would classify a similar dismissal.
Can a second forum apply its own preclusion rules to reduce the effect of a state court limitations dismissal?+
No. The rendering state's characterization of its judgment as on the merits controls. A later court may not substitute its own view that limitations dismissals lack preclusive effect.
Does the claim-preclusive effect of a federal diversity judgment dismissing an action on limitations grounds follow federal or state law?+
It follows the law of the state in which the federal court sits. Federal common law adopts the preclusion rules of the forum state for diversity judgments.
531 U.S. 497 (2001)Conflict of Laws
…Justice Scalia delivered the opinion of the Court. Opinion of Justice Scalia This case presents the question whether the claim-preclusive effect of a federal judgment dismissing a diversity action on statute-of-limitations grounds is determined by the law of the State in which the federal court sits. I Petitioner filed a…