Law School Case Brief
Hoult v. Hoult - 157 F.3d 29 (1st Cir. 1998)
When an issue of fact or law is actually litigated and determined by a valid and final judgment, and the determination is essential to the judgment, the determination is conclusive in a subsequent action between the parties, whether on the same or a different claim.
In July 1988, when she was 27 years old, Jennifer Hoult (Jennifer) brought suit in the district court against her father, David Hoult (David), alleging assault and battery, intentional infliction of emotional distress, and breach of fiduciary duty. To support these claims, she alleged that her father had sexually abused, raped, and threatened her from the time that she was about four years old until she was about 16 years old. The jury awarded damages to Jennifer. David’s appeal of the decision was dismissed for lack of prosecution. Thereafter, David brought a defamation action against Jennifer after she repeated her charges of rape to several professional associations. The trial court dismissed the action on the ground that David was barred by the doctrine of collateral estoppel from re-litigating the issue of whether or not he had raped Jennifer.
Was David barred by the doctrine of collateral estoppel from re-litigating the issue of whether or not he had raped Jennifer?
The Court held that the present lawsuit sought, in the guise of a defamation action, to retry the central issue in the prior assault case between the same litigants. That issue--ultimately a credibility contest between the two opposing parties--was resolved by the jury at the first trial. According to the Court, whether the jury was right or wrong, its decision about what happened was not now open to relitigation; therefore, David was collaterally estopped from re-litigating the issue.
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