Law School Case Brief
River Park v. City of Highland Park - 184 Ill. 2d 290, 234 Ill. Dec. 783, 703 N.E.2d 883 (1998)
The same evidence test is not determinative of identity of cause of action, in determining whether causes of action are the same for purposes of res judicata. Instead, pursuant to the transactional analysis, separate claims will be considered the same cause of action for purposes of res judicata if they arise from a single group of operative facts, regardless of whether they assert different theories of relief. Of course, under the transactional analysis, the nature of the evidence needed to prove the claims at issue remains relevant for purposes of demonstrating that the claims arise from the same group of operative facts. Unlike the same evidence test, however, the transactional test permits claims to be considered part of the same cause of action even if there is not a substantial overlap of evidence, so long as they arise from the same transaction.
Plaintiff developers sought damages based on defendant City of Highland Park, which refused to approve a development plan and rezoning request. Plaintiffs first sought relief under 42 U.S.C.S. § 1983 against defendant City in the federal court, which was dismissed. Plaintiffs subsequently sued in the trial court. The trial court dismissed the complaint pursuant to 735 Ill. Comp. Stat. 5/2-619. The intermediate state appellate court affirmed the trial court's dismissal of the developers' tortious interference claim but reversed the dismissal of claims for breach of implied contract and abuse of governmental power. Defendant City sought further appellate review, contending that plaintiffs' claims were barred by the doctrine of res judicata.
Were developers' claims for breach of implied contract and abuse of governmental power against a City barred by the doctrine of res judicata?
On defendant's appeal, the Supreme Court of Illinois reversed in part the lower appellate court's judgment and affirmed the trial court's judgment, holding that plaintiffs' claims were barred by res judicata. There was an identity of parties and of cause of action. Under a transactional test, there was no material difference between plaintiffs' federal and state causes of action. The federal court's dismissal for failure to state a cause of action, not for subject matter jurisdiction, was a final judgment on the merits. Plaintiffs had filed no state claims in the federal court, but the state claims could have been decided in the federal suit.
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