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A final judgment rendered by a court of competent jurisdiction on the merits is conclusive as to the rights of the parties and their privies, and, as to them, constitutes an absolute bar to a subsequent action involving the same claim, demand or cause of action. Thus, before an adjudication can stand as a bar to a subsequent action, it must be determined whether the first action resulted in a final judgment on the merits.
The Illinois general assembly passed legislation, subsequently signed by the governor, that provided for the conveyance by the state of 194.6 acres of land submerged in waters of Lake Michigan to the defendant steel corporation. The attorney general filed an action seeking a declaratory judgment that the legislation was void. The circuit court granted the attorney general’s motion for summary judgment. On appeal, the defendant corporation contended that previous cases considered by the court regarding the legislation at issue operated as a bar under the doctrine of res judicata to the attorney general's challenge to the validity of the legislative action.
The court ruled that when a cause of action was dismissed on the ground that the plaintiff lacked standing, as in the earlier cases, the court need not have considered the substantive issues involved, amounting to an adjudication on the merits. The court affirmed the summary judgment for the attorney general that the legislation was void on the ground that it violated the public trust doctrine because the primary purpose was private and the public benefit was only incidental and remote.