Also known as: res judicata · resjudicata · claim preclusion
Written by attorneys · grounded in primary & secondary sources — see below
A doctrine that prevents relitigation of claims or issues already resolved by a final judgment on the merits between the same parties or their privies. The doctrine promotes finality and judicial economy by treating a valid prior judgment as conclusive on the matters it decided. Jurisdictions differ on whether certain procedural dismissals qualify as judgments on the merits for preclusion purposes.
Diego Duarte sued Danielle Dixon in state court over a contract dispute. The court dismissed the action after the statute of limitations expired. Duarte later filed the same claim in federal court. The federal court must decide whether the state dismissal counts as a judgment on the merits that bars the new suit under claim preclusion principles.
Several patients obtained a final negligence judgment against Valley Compounding Pharmacy for contaminated medication. The patients then sued National Pharmaco Distributors for supplying ingredients to the same batches. The court applies ordinary res judicata rules to determine whether the prior judgment has preclusive effect on the claims against the second supplier.
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The SEC obtained a judgment against Parklane Hosiery for securities violations. A private shareholder later sued the same company and sought to use the SEC findings to establish the violations. The court evaluates whether fairness permits the offensive use of the prior judgment to bind the defendant on the litigated issues.
Northern Pipeline sued Marathon Pipe Line in bankruptcy court over a contract dispute. Marathon challenged the bankruptcy court's power to enter a final judgment on the state-law claim. The court considers whether the prior proceedings carry preclusive effect given limits on the tribunal's jurisdiction.
Shareholders obtained a final judgment dismissing their securities claims under a limitations rule announced in Lampf. Congress later enacted a statute that would revive the dismissed claims. The court determines whether the new statute can reopen the final judgments without violating separation of powers.
A Michigan court enjoined a former employee from testifying against General Motors in product-liability cases. The employee later sought to testify in a Missouri proceeding. The Missouri court must decide whether full faith and credit requires it to honor the Michigan injunction as res judicata on the testimony issue.
No. The effect of a judgment for or against one of several tortfeasors on claims against others liable for the same harm is governed by ordinary res judicata principles rather than any automatic rule. A prior judgment may have preclusive consequences only if the usual elements of claim or issue preclusion are satisfied.
Supporting sources
Federal Rule of Civil Procedure 41(b) does not itself decide the question. Jurisdictions may treat a limitations dismissal as on the merits or not, and a later court applies the rendering jurisdiction's rule to determine preclusive effect.
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…