Also known as: conclusiveness of the judgment · conclusive judgment doctrine · judgment conclusiveness · res judicata · claim preclusion
Written by attorneys — see sources 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.
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.
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.
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.
In 1979 the Cleveland Board of Education hired James Loudermill as a security guard. On his job application Loudermill stated that he had never been convicted of a felony. Eleven months later a routine check revealed that Loudermill had been convicted of grand larceny in 1968. By letter dated November 3, 1980 the Board's Business Manager informed Loudermill that he had been dismissed for dishonesty in filling out the employment application. Loudermill received no opportunity to respond to the charge or to challenge the dismissal before it took effect. Under Ohio law Loudermill was a classified civil servant who could be discharged only for cause and who could file an administrative appeal within ten days of receiving notice of dismissal. Loudermill filed an appeal with the Cleveland Civil Service Commission on November 12, 1980. A referee held a hearing on January 29, 1981 and recommended reinstatement. On July 20, 1981 the full Commission heard argument and upheld the dismissal. Richard Donnelly was hired as a bus mechanic by the Parma Board of Education in 1979. Donnelly had been fired by the same Board in 1977 for failing an eye examination but had been reinstated after appeal. On his new application Donnelly listed his prior employment with the Board but did not disclose the earlier discharge. When the omission was discovered Donnelly was again fired for dishonesty. He received no opportunity to respond to the charge before termination. Donnelly appealed to the Civil Service Commission, which affirmed the dismissal. Loudermill and Donnelly filed separate suits in the Federal District Court for the Northern District of Ohio alleging that the dismissal procedures violated their rights to procedural due process under the Fourteenth Amendment. The District Court dismissed both complaints for failure to state a claim. The Court of Appeals for the Sixth Circuit reversed in part and remanded. The Supreme Court granted certiorari.
View caseDestiny 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.
In 1987 petitioners filed a civil action in the United States District Court for the Eastern District of Kentucky against respondents. The complaint alleged that respondents had committed fraud and deceit in the sale of stock in 1983 and 1984 in violation of section 10(b) of the Securities Exchange Act of 1934 and Rule 10b-5. The District Court dismissed the action as time barred under the then-applicable Kentucky statute of limitations. While petitioners' appeal was pending in the Court of Appeals for the Sixth Circuit, the Supreme Court decided Lampf, Pleva, Lipkind, Prupis & Petigrow v. Gilbertson on June 20, 1991. The next day the Court applied that decision to dismiss another pending appeal. The Sixth Circuit remanded petitioners' case to the District Court for further proceedings in light of Lampf. On August 13, 1991, the District Court dismissed the action with prejudice under the Lampf statute of limitations. Petitioners filed no appeal, and the judgment became final thirty days later on December 18, 1991. On December 19, 1991, the President signed the Federal Deposit Insurance Corporation Improvement Act of 1991. Section 476 of that Act added section 27A to the Securities Exchange Act of 1934. Subsection (b) provides that any private civil action under section 10(b) commenced on or before June 19, 1991, which was dismissed as time barred after that date and which would have been timely under the limitation period provided by the laws applicable in the jurisdiction as such laws existed on June 19, 1991, shall be reinstated on motion by the plaintiff not later than sixty days after December 19, 1991. Petitioners promptly filed a motion under section 27A(b) to reinstate their action. The District Court denied the motion. The Court of Appeals for the Sixth Circuit reversed, and the Supreme Court granted certiorari.
View caseDillon 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.
In 1978 Congress enacted the Bankruptcy Reform Act after nearly ten years of study. The statute established a United States bankruptcy court in each judicial district as an adjunct to the district court. It granted those courts jurisdiction over all civil proceedings arising under title 11 or arising in or related to cases under title 11. Bankruptcy judges appointed under the Act served fourteen-year terms. They were subject to removal by the judicial council of the circuit for incompetence, misconduct, neglect of duty, or disability. They received salaries subject to congressional adjustment. In January 1980 Northern Pipeline Construction Co. filed a petition for reorganization under the Act in the United States Bankruptcy Court for the District of Minnesota. In March 1980 Northern filed a separate suit in the same court against Marathon Pipe Line Co. seeking damages for alleged breaches of contract and warranty as well as for misrepresentation, coercion, and duress. Marathon moved to dismiss the suit on the ground that the Act unconstitutionally conferred Article III judicial power on bankruptcy judges who lacked life tenure and salary protection. The United States intervened to defend the statute. The Bankruptcy Court denied the motion to dismiss. On appeal the District Court reversed and dismissed the suit. Northern and the United States filed notices of appeal, and the Supreme Court noted probable jurisdiction.
View caseDemetrius 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, along with his wife Harriet and their two children Eliza and Lizzie, was held as a slave by the defendant John F. A. Sandford in the State of Missouri. Scott initiated an action in the Circuit Court of the United States for the District of Missouri asserting his and his family's right to freedom. The declaration averred that Scott was a citizen of Missouri and the defendant a citizen of New York to establish diversity jurisdiction. The defendant responded with a plea in abatement asserting that the court lacked jurisdiction because Scott was not a citizen of Missouri. Scott was a negro of African descent whose ancestors were of pure African blood and had been brought into the country and sold as slaves. Scott demurred to this plea. The Circuit Court overruled the plea and required the defendant to answer over. The defendant then filed pleas in bar. After a trial on the merits the jury returned a verdict in favor of the defendant, leading to judgment for him. Scott then prosecuted a writ of error to the Supreme Court. The underlying facts showed that Scott had been the slave of Dr. Emerson, a surgeon in the United States Army. In 1834 Emerson took Scott from Missouri to Rock Island in Illinois, where he held him as a slave until 1836. Emerson then removed Scott to Fort Snelling in the Territory of Upper Louisiana north of thirty-six degrees thirty minutes north latitude, holding him there until 1838. Harriet, originally the slave of Major Taliaferro, was also brought to Fort Snelling and sold to Emerson. Scott and Harriet were married at Fort Snelling in 1836 with Emerson's consent, and their children were born there or during the return journey. In 1838 Emerson brought the family back to Missouri, where they resided until Emerson sold them to Sandford. The case reached the Supreme Court after two arguments. The Court ordered reargument on some of the points due to differences of opinion among the justices and the importance of the questions involved.
View caseNo. 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.
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.
No. The doctrine requires that the rendering court have competent jurisdiction. A judgment entered without jurisdiction lacks preclusive effect.
Yes. Once a judgment becomes final, the doctrine treats it as conclusive and immune from legislative abrogation.
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.
…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…