Under California law, the claim preclusion aspect of res judicata, also referred to as bar or merger, precludes the maintenance of a second suit between the same parties on the same cause of action so long as the first suit concluded in a final judgment on the merits. All issues that were litigated or that might be litigated as part of the cause of action are barred.
Plaintiffs, a civil rights organization and others, brought a class action against defendants, school district and officials, alleging intentional segregation in the public schools. Defendants filed a motion for summary judgment on the ground that plaintiffs were seeking to relitigate the same claim that had been litigated and decided in a prior case. The previous case was a class action brought on behalf of all black and Hispanic students attending school in defendants' district, and in that case, the appellate court reversed the trial court's desegregation order.
Does res judicata bar litigation between the same parties for the same issues?
The Court held that relitigation of the de jure segregation claim was barred by the doctrine of res judicata because the primary right underlying de jure and de facto claims of both suits were one and the same, the right to an equal opportunity for education. The court held that the bar applied only to events occurring on or before the close of the trial in the prior suit. The court reversed and remanded the decision that had denied the motion of defendants, school district and officials, for summary judgment in a class action alleging intentional segregation in public schools. The court held that relitigation of the de jure segregation claim was barred by the doctrine of res judicata because the primary right enforced in a prior suit was the same as the primary right asserted in the present action.