Also known as: res judicata · claim preclusion · res judicata claim preclusion
Written by attorneys · grounded in primary & secondary sources — see below
A doctrine providing that a final judgment on the merits rendered by a court of competent jurisdiction precludes the parties or their privies from relitigating the same claim in a subsequent action.
Rina Rahman sued Roger Ramirez in federal court in State X for breach of a supply contract. The court dismissed the action after applying State X's shorter statute of limitations. Rina then filed the identical claim in State Y court where the limitations period remained open. The State Y court consults its own preclusion principles to decide whether the prior federal dismissal counts as a judgment on the merits that bars the new suit.
Raven Logistics and Radiance Media were both sued for the same cargo damage arising from a single shipment accident. A court entered judgment against Raven Logistics after full litigation of the negligence claim. Radiance Media later faced a separate suit by the same plaintiff for identical harm. The second court applies res judicata principles to determine the effect of the first judgment on the remaining tortfeasor.
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Ralph Richardson brought a class action alleging misleading proxy statements in a corporate merger. An earlier SEC enforcement action against the same defendants produced a final judgment finding the statements false and misleading. Ralph moved for summary judgment in his damages suit relying on the prior determination. The court evaluates whether the earlier judgment has preclusive effect on the new suit.
Regina Robinson sued Piper Aircraft in a U.S. court for a plane crash occurring abroad. The court dismissed the action on forum non conveniens grounds after determining Scotland provided an adequate alternative forum. Regina refiled the identical wrongful death claim in state court. The new court determines whether the federal dismissal operates as a merits adjudication for claim preclusion purposes.
Ryan Roberts sued a university foundation for patent infringement. An earlier suit by the foundation against another party resulted in a final judgment invalidating the same patent. Ryan seeks to rely on that invalidity finding to defeat the infringement claim. The court assesses whether the prior judgment has preclusive effect on the new suit.
Rowan Russell, a shareholder, filed a class action in federal court challenging a corporate merger. A prior state court class action involving the same merger and substantially identical claims produced a final judgment approving the settlement. Rowan argues the federal suit is not barred because the state court lacked personal jurisdiction over absent class members. The federal court applies claim preclusion principles to decide whether the state judgment binds the new class.
No. A limitations dismissal is not automatically treated as an adjudication on the merits for claim preclusion purposes. Jurisdictions differ on whether such a dismissal precludes refiling elsewhere, and federal common law in diversity cases typically incorporates the preclusion law of the rendering state.
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The effect is determined by res judicata principles. A judgment for or against one tortfeasor does not automatically bind or release others unless the judgment after trial on the merits makes the liability of one dependent on the liability of the other.
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Yes. A party who fails to assert a compulsory counterclaim arising from the same transaction or occurrence forfeits that claim. Claim preclusion then prevents the party from bringing the omitted claim in a later action.
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…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…