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Friends for All Children v. Lockheed Aircraft Corp. - 497 F. Supp. 313 (D.D.C. 1980)

Rule:

The law of the District of Columbia permits the use of offensive collateral estoppel. Assuming that offensive collateral estoppel is available as a matter of law, its application to particular cases is a matter within the discretion of the trial court.

Facts:

Plaintiff James Reynolds, on behalf of an injured infant, moved for a ruling in limine to prevent defendant Lockheed Aircraft Corp. (Lockheed) or third-party defendant the United States from relitigating certain issues assertedly decided in Reynold's favor arising from the same crash event. The prior cases were of Schneider v. Lockheed, No. 76-0544-1, and Marchetti v. Lockheed, No. 76-0544-3. Defendant Lockheed opposed Reynold's motion, maintaining that the circumstances of those cases were not appropriate for the application of offensive collateral estoppel.

Issue:

Was the offensive collateral estoppel applicable in this case?

Answer:

Yes

Conclusion:

The court granted the motion. It held as a matter of law that it was permitted to apply offensive collateral estoppel to such an appropriate case. First, none of the plaintiffs could have joined the prior actions because of Lockheed’s opposition. Thus, the use of collateral estoppel in these actions did not undermine judicial efficiency by encouraging plaintiffs not to join similar claims against Lockheed. Second, there was no unfairness since all of the claims were filed simultaneously. Lockheed had a fair opportunity to present proof on the issues that plaintiff sought to foreclose. Finally, it was not unfair to give the verdicts in these cases future effect. The pendency of as many as 147 other damage claims, all arising out of the same occurrence, called for the use of principles, such as collateral estoppel, that would limit costly and repetitive litigation. Lockheed received their fair opportunity to litigate their claims and preclusion in the future cases of these determinative issues balanced all of the parties' interests and served the interests of judicial efficiency.

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