Also known as: res adjudicatae · res judicata · res judicatae
Written by attorneys · grounded in primary & secondary sources — see below
The rule that the preclusive effect of a judgment for or against one of several tortfeasors upon claims against others who were or may have been liable for the same harm is determined by the principles of res judicata.
Ronald Reed sued a nonprofit host after a stage collapse injured him at a charity event and lost after a full trial on negligence and causation. He then sued the stage rental company and a volunteer planner for the same injuries from the same accident. The prior judgment controls the new claims under res judicata principles and bars relitigation of the same harm.
After a plaintiff lost a negligence suit against one driver in a multi-car collision, she filed an identical claim against the second driver for the same injuries. The prior judgment determines the preclusive effect on the second driver under res judicata principles and bars relitigation of the same harm.
Select any source to read its text and confirm it supports the definition.
After an SEC action established falsity against a company, a shareholder sued additional officers for the same securities fraud. The prior judgment could be used offensively against the officers under res judicata principles because they shared a full opportunity to litigate the issue.
Dred Scott sued for freedom in federal court after a state court had already adjudicated his status as a slave. The prior state judgment operated as res judicata and barred relitigation of the same claim against additional parties potentially liable for the same restraint.
Shareholders obtained a final judgment dismissing their securities claims against one set of defendants. Congress later enacted a statute that would have allowed the same claims to be refiled against additional responsible parties. The statute could not override the res judicata effect of the prior judgment.
An estate obtained a state-court ruling on the validity of a will against one claimant. The IRS later challenged the same issue in a federal tax proceeding against additional interested parties. The state judgment was res judicata and bound the federal court on the question of state law.
No. The effect of a judgment for or against one of several tortfeasors on claims against others is determined by the principles of res judicata rather than by any automatic rule. A prior defense verdict on negligence and causation can preclude relitigation of the same harm against different defendants when the doctrines of claim or issue preclusion apply.
Supporting sources
The effect is governed by ordinary claim-preclusion and issue-preclusion rules. Claim preclusion requires the same parties or their privies. Issue preclusion can bind a plaintiff on issues actually litigated and necessarily decided even against different defendants when nonmutual defensive issue preclusion is permitted.
Supporting sources
…does not deny or limit litigants' rights to a federal forum "because state administrative agency determinations do not create res judicata or collateral estoppel effects. The exhaustion of state administrative remedies postpones rather than precludes the assertion of federal jurisdiction." Comment, Exhaustion of State…