Also known as:conclusiveness of the judgment · conclusive judgment doctrine · judgment conclusiveness · res judicata · claim preclusion
Written by attorneys · grounded in primary & secondary sources — see below
A principle holding that a final judgment by a court of competent jurisdiction conclusively determines the rights of the parties with respect to the claim or issue decided. The judgment bars relitigation of the same claim between the same parties or their privies.
Sources & Authorities
How it applies
Common Examples
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Limitations Dismissal and New Filing
Dustin Donovan sued a supplier in state court for breach of contract but the action was dismissed after the statute of limitations expired. Donovan later filed the identical claim in federal court. The federal court permitted the second action because the prior dismissal did not count as an adjudication on the merits for claim-preclusion purposes.
Judgment Against One Tortfeasor
Dakota Industries obtained a judgment against one of two joint tortfeasors for property damage caused by a single incident. When Dakota later sued the second tortfeasor on the same harm, the court applied res judicata principles to determine the effect of the first judgment on the remaining claim.
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Cases
Restatements
Dictionaries
Due Process Hearing Requirement
Dominic Drake was terminated from public employment without any pre-termination hearing. Drake sued the employer claiming a violation of procedural rights. The court examined whether the prior administrative decision conclusively resolved the adequacy of the process afforded.
Cleveland Board of Education v. Loudermill470 U.S. 532, 541 (1985)
Legislative Attempt to Reopen Case
Destiny Davis obtained a final judgment dismissing a securities action. Congress later enacted a statute that would have allowed Davis to refile the same claim. The court held that the new statute could not reopen the concluded judgment.
Plaut v. Spendthrift Farm, Inc.514 U.S. 211, 228 (1995)
Bankruptcy Court Authority Dispute
Dillon Energy obtained a judgment in a contract dispute. The losing party later argued in bankruptcy proceedings that the original court lacked authority to decide the matter. The court treated the prior judgment as conclusive on the question of authority.
Northern Pipeline Construction Co. v. Marathon Pipe Line Co.458 U.S. 50, 102 S.Ct. 2858 (1982)
Citizenship Determination Binding
Demetrius Douglas was held to be a non-citizen in a prior proceeding. In a later action seeking different relief, the court treated the earlier citizenship ruling as conclusive between the parties.
Dred Scott v. Sandford60 U.S. (19 How.) 393
Common questions
Frequently Asked
5
Does a dismissal for failure to join an indispensable party count as a judgment on the merits for claim preclusion?+
No. Under the doctrine, such a dismissal does not operate as an adjudication on the merits and therefore does not bar a subsequent action on the same claim.
How does the doctrine apply when a judgment is entered against one of several joint tortfeasors?+
The effect of that judgment on claims against the remaining tortfeasors is governed by res judicata principles that determine whether the first judgment conclusively resolves the shared harm.
Can a judgment rendered by a court lacking subject-matter jurisdiction be conclusive?+
No. The doctrine requires that the rendering court have competent jurisdiction. A judgment entered without jurisdiction lacks preclusive effect.
Does the doctrine prevent Congress from reopening a final civil judgment?+
Yes. Once a judgment becomes final, the doctrine treats it as conclusive and immune from legislative abrogation.
When does a limitations dismissal bar a later identical claim?+
It does not. Jurisdictions may treat a statute-of-limitations dismissal as not on the merits, allowing the same claim to be pursued in another forum.
431 U.S. 494, 503 (1977)Property
…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…