The classic situation in which the doctrine of res judicata comes into play is where a second claim between the same parties is based on the same operative facts as the earlier one. The issues tried in the first claim and any other issues which could have been dealt with there are forever barred by the first judgment. Thus, the question is whether the claim alleged in the second complaint is the same as that in the suit concluded earlier. The term "claim" refers to a group of facts limited to a single occurrence or transaction without particular reference to the resulting legal rights. It is the facts surrounding the occurrence which operate to make up the claim, not the legal theory upon which a plaintiff relies.
Plaintiff brought an action against the defendants, New York Racing Association, Inc. and Thoroughbred Racing Protective Association Inc., a private detective agency employed by the Racing Association for security purposes. According to the plaintiff, the employees of the detective agency assaulted, kidnapped, falsely arrested and falsely imprisoned him and charged him with disorderly conduct and maliciously caused him to be prosecuted and convicted in the Magistrate's Court of the City of New York. He sought relief in the form of money damages and an injunction restraining the defendants from interfering with his attendance at race tracks, from publication of libelous statements, and from acting as peace officers. The defendants move for summary judgment, asserting that a prior judgment was entered based on the same facts, although the named defendants were the employees of the race track owner and the detective agency. In their view, a judgment in a prior action in the court is res judicata as to the claim alleged in the complaint.
Should the doctrine of res judicata apply in the present claim?
The doctrine of res judicata operates as a bar to subsequent suits involving the same parties, or those in privity with them, based on a claim which has once reached a judgment on the merits. The Court held that there is no doubt that the parties in this action are in privity with those in the earlier suit since a corporation acts only through its agents, and if the agents are not at fault, there is no basis for corporate liability; therefore, the Court posited that the same facts are the basis for liability in each suit. It also argued that the plaintiff cannot be permitted to splinter his claim into a multiplicity of suits and try them piecemeal at his convenience. The Court was cognizant of the fact that plaintiff appears pro se, but as the law provides a beginning for litigation, it must also provide an end. The doctrine of res judicata is a barrier against needless multiplication of litigation.