Also known as: res judicatae · claim preclusion
Written by attorneys · grounded in primary & secondary sources — see below
A doctrine that bars a party from relitigating a claim that was or could have been raised in a prior action between the same parties once a court has entered a final judgment on the merits. The doctrine promotes finality by treating the prior judgment as conclusive on the entire claim. Jurisdictions differ on whether certain procedural dismissals count as judgments on the merits for preclusion purposes.
Riverside Healthcare sued Regal Apparel in federal court for unpaid invoices. The court dismissed the action after Regal Apparel proved the statute of limitations had run. Riverside Healthcare later filed the identical claim in state court. The state court treated the federal dismissal as a judgment on the merits and barred the second suit under res judicata.
Ryan Roberts obtained a judgment against Riverstone Manufacturing for injuries caused by a defective machine. Roberts then sued Regal Apparel, the distributor that had supplied the same machine. The court applied res judicata principles to determine whether the prior judgment against the manufacturer affected the claim against the distributor.
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Rosalind Reed sued in Florida to invalidate a trust holding Delaware assets. The Delaware trustee never appeared in the Florida action. After the Florida court ruled the trust invalid, the trustee sought a contrary ruling in Delaware. The Delaware court refused to treat the Florida judgment as preclusive because it lacked jurisdiction over the trustee.
Royal Crest Hotels challenged an Illinois anti-takeover statute in federal court. A prior state-court declaratory judgment had upheld a similar statute. The federal court considered whether the earlier judgment precluded the new constitutional challenge under res judicata principles.
Renata Russo sued Parklane Hosiery after the SEC obtained a judgment finding the company had violated securities laws. Russo sought to use the SEC finding to establish the violation in her own damages action. The court evaluated whether res judicata principles permitted offensive use of the prior judgment against the company.
Roger Ramirez obtained a final federal judgment dismissing his securities claim. Congress later enacted a statute that would have revived the claim. Ramirez argued the new statute overrode the prior judgment. The court held that res judicata prevented Congress from reopening the final judgment.
No. Federal Rule of Civil Procedure 41(b) expressly excludes dismissals based on failure to join an indispensable party from operating as an adjudication on the merits. Jurisdictions may still treat other procedural dismissals differently for preclusion purposes.
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The effect is governed by res judicata principles. A judgment for or against one tortfeasor does not automatically bind others unless the judgment meets the requirements of claim or issue preclusion.
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No. A judgment rendered without jurisdiction over the party has no preclusive effect against that party. The prior judgment must have been entered by a court with jurisdiction for res judicata to apply.
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Yes. Separation of powers principles bar Congress from legislatively reopening final judgments of Article III courts. Res judicata protects the finality of those judgments against retroactive legislative interference.
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…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…