Also known as:former adjudications · res judicata · claim preclusion
Written by attorneys · grounded in primary & secondary sources — see below
A judgment rendered in a prior action that finally determines the rights of the parties or essential fact questions. The judgment bars relitigation of the same claims under res judicata or the same issues under collateral estoppel.
Sources & Authorities
How it applies
Common Examples
6
Limitations Dismissal in Admiralty
A broker sued a shipping company in state court for unpaid commissions on maritime services. The court dismissed the action after the statute of limitations expired. The broker filed the same claims in federal admiralty court. The federal court permitted the new action because the prior dismissal did not count as an adjudication on the merits for claim preclusion purposes.
Judgment Against One Tortfeasor
A plaintiff obtained a judgment against one driver for injuries from a car accident. The plaintiff later sued the second driver who shared responsibility for the same collision. The court applied res judicata principles to determine whether the first judgment affected the claim against the second driver.
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Cases
Restatements
Casebooks
Hornbooks
Course Outlines
Dictionaries
Congressional Attempt to Reopen
Investors obtained a final judgment dismissing their securities claims against a farm. Congress later passed a statute that would have allowed the investors to refile the same claims. The court held that the statute could not reopen the already-final judgments.
Plaut v. Spendthrift Farm, Inc.514 U.S. 211, 228 (1995)
Habeas Challenge to Search
A defendant convicted in state court sought federal habeas relief claiming an unconstitutional search. The federal court refused to relitigate the Fourth Amendment issue because the state courts had already decided it after full and fair opportunity.
Stone v. Powell428 U.S. 465 (1976)
Offensive Use by Shareholder
The SEC first obtained a judgment against corporate officers for issuing a false proxy statement. A shareholder then sued the same officers for damages from the identical false statement. The shareholder moved to prevent the officers from relitigating the falsity issue.
Parklane Hosiery Co. v. Shore439 U.S. 322, 334 (1979)
Prior Immunity Determination
A prosecutor obtained dismissal of a civil rights suit on absolute immunity grounds. The same plaintiff later filed a new action based on the identical prosecutorial conduct. The court treated the immunity ruling as binding in the second suit.
Imbler v. Pachtman424 U.S. 409 (1976)
Common questions
Frequently Asked
3
When does a statute-of-limitations dismissal count as an adjudication on the merits for claim preclusion?+
A limitations dismissal does not automatically qualify as an adjudication on the merits. Jurisdictions may decide whether such a dismissal bars a later action asserting the same claim.
Supporting sources
How does a judgment against one tortfeasor affect claims against others liable for the same harm?+
The effect is governed by res judicata principles. A judgment for or against one tortfeasor may bind or preclude claims against additional tortfeasors depending on those principles.
Supporting sources
Does offensive nonmutual issue preclusion always apply when a prior judgment exists?+
Offensive nonmutual issue preclusion requires fairness to the defendant in light of all circumstances. Courts examine whether the defendant had a full and fair opportunity to litigate the issue in the first action.
Supporting sources
357 U.S. 235 (1958)Conflict of Laws
…her children pursued their own interests. When the Florida decree was entered the legatees unsuccessfully urged it as res judicata of the Delaware dispute. In a decree dated Jan. 13, 1956, the Delaware Chancellor ruled that the trust and power of appointment were valid under the applicable Delaware law, and that the…