Also known as: claim-preclusive · claim preclusion
Written by attorneys · grounded in primary & secondary sources — see below
A judgment or dismissal that bars relitigation of the same claim between the same parties. The characterization turns on whether the rendering jurisdiction treats the disposition as an adjudication on the merits.
Carlos Castillo sued Citadel Security in State A superior court for breach of a security services contract. The court dismissed the action with prejudice because the four-year limitations period had run and State A law treats such dismissals as adjudications on the merits. Castillo then filed the identical claim in federal court in State B. The federal court must apply State A preclusion rules to determine whether the State A judgment is claim preclusive.
Cassandra Cooper obtained a Michigan injunction against General Motors that resolved her wrongful-discharge and contract claims. She later attempted to relitigate those same claims in another forum. The Michigan judgment merged the claims and prevented her from pursuing additional recovery against the same defendant.
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Curtis Cannon was not a party to an earlier suit brought by a different plaintiff against the same defendant. He sought to assert a claim that would have been barred if he had been in privity with the prior plaintiff. The court examined whether the earlier judgment could bind him under principles of representation or control.
Carmen Choi filed a class action in federal court seeking statutory damages under state law. The defendant argued that a state procedural rule limiting class actions should prevent the suit from proceeding. The court analyzed whether the federal rule governing class certification displaced the state limitation for purposes of allowing the claim to go forward.
No. Whether the dismissal is claim preclusive depends on the law of the rendering jurisdiction. Some states treat limitations dismissals as adjudications on the merits while others do not. A later court must apply the rendering court's preclusion rules.
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Full faith and credit requires the federal court to apply the rendering state's preclusion law. The federal court cannot substitute its own view of whether a limitations dismissal counts as on the merits.
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No. The rule addresses only the effect within the same federal proceeding. It leaves jurisdictions free to decide whether particular dismissals, such as those based on limitations, carry preclusive effect in later actions.
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…effect of federal diversity judgments is prescribed by federal law, under which the earlier dismissal was on the merits and claim preclusive. 128 Md. App. 39, 736 A. 2d 1104 (1999). After the Maryland Court of Appeals declined to review the case, we granted certiorari. 530 U. S. 1260 (2000). II Petitioner contends that the…