Also known as: collateral estoppel by judgement · estoppel by judgment · collateral estoppel · issue preclusion
Written by attorneys · grounded in primary & secondary sources — see below
An issue-preclusion doctrine under which a valid and final judgment conclusively determines an ultimate fact or issue that was actually litigated and necessarily decided in a prior action. The determination bars relitigation of that same issue in a later proceeding involving the same parties or their privies, even when the second action rests on a different claim or charge.
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Luis stood trial for robbing Carla during a bus holdup. The jury acquitted him after the only contested issue was whether he was one of the masked robbers. The prosecutor then charged Luis with robbing Daniel, another passenger on the same bus, relying on the identical video and eyewitness testimony. The court must dismiss the new charge because the prior acquittal resolved the identity issue in Luis's favor.
Leo was acquitted of robbing Maria at a museum fundraiser after the jury doubted he was the masked gunman. The state then charged Leo with robbing Daniel, another victim at the same event, using the same surveillance images and witnesses. Because the first jury necessarily decided the identity issue against the state, the second prosecution is barred.
The SEC obtained a judgment that Citadel Security violated securities laws by issuing a false proxy statement. South Grid, a class of investors harmed by the same statement, then sued Citadel for damages and moved for summary judgment on the violation element. The court may grant the motion and preclude Citadel from relitigating the falsification issue.
Harbor Consortium financed and directed the defense in an earlier suit challenging a port fee schedule. After losing that case, Harbor Consortium filed its own refund action asserting the same fee methodology was invalid. The prior determination that the methodology was lawful binds Harbor Consortium because it controlled the first litigation.
Caleb Chang was charged with multiple environmental violations arising from the same waste-dumping episode. He successfully moved to sever the counts for separate trials. After acquittal on the first count, the state sought to try the remaining counts. The court permits the later trials because Chang's own severance request removed any preclusive effect from the first acquittal.
Central Dynamics lost an infringement suit brought by a university foundation after the court found its product infringed a valid patent. In a later declaratory-judgment action against a different licensee, Central Dynamics again challenged the patent's validity. The earlier determination that the patent was valid precludes Central Dynamics from relitigating that issue.
Yes. When the only contested issue in the first trial was the defendant's identity as the perpetrator and the jury acquitted, that determination bars a later prosecution for the same episode even if the second charge names a different victim. The identity issue was necessarily decided in the defendant's favor and cannot be relitigated.
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…the extensive involvement from the inception of this litigation by the Department of State and AID.[^maj-19] Under principles of collateral estoppel, these agencies are precluded from subsequently relitigating the issues decided in this suit. "[O]ne who prosecutes or defends a suit in the name of another to establish and protect his…
…and Procedure § 2522, pp. 244-246 (2d ed. 1995). See also Parklane Hosiery Co. v. Shore , 439 U. S. 322, 335-337 (1979) (issue preclusion
…The District Court held that the estoppel doctrine applied, and the Court of Appeals affirmed. Held: 1. The doctrine of collateral estoppel
…was whether the petitioner was one of the robbers, and the first jury by its verdict found that he was not. The doctrine of collateral estoppel
…however, later described Dewey as resting instead on the doctrine of equitable estoppel and on “themes of res judicata and
Yes. When the defendant elects to sever charges that could have been tried together, the first acquittal does not bar subsequent trials on the severed counts. The defendant's consent to separate trials removes the preclusive effect that would otherwise attach under double jeopardy.
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No. Courts look only to what the acquittals necessarily decided. A hung count on other charges does not undermine the preclusive force of the acquittals on common factual issues, and retrial is barred on those issues.
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It is fair when the defendant had a full and fair opportunity to litigate the issue in the first action, the stakes were comparable, and no procedural differences or other circumstances create inequity. Courts weigh the defendant's incentive to litigate, the availability of a jury, and the risk of unfair surprise.
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Yes. A nonparty that assumed control over litigation in which it had a direct financial or proprietary interest is bound by the resulting determination of issues actually and necessarily decided. The prior judgment is conclusive in later suits on a different cause of action.
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