Taylor v. Strugell

553 U.S. 880, 128 S. Ct. 2161 (2008)



The preclusive effect of a judgment is defined by claim preclusion and issue preclusion, which are collectively referred to as "res judicata." Under the doctrine of claim preclusion, a final judgment forecloses successive litigation of the very same claim, whether or not relitigation of the claim raises the same issues as the earlier suit. Issue preclusion, in contrast, bars successive litigation of an issue of fact or law actually litigated and resolved in a valid court determination essential to the prior judgment, even if the issue recurs in the context of a different claim. By precluding parties from contesting matters that they have had a full and fair opportunity to litigate, these two doctrines protect against the expense and vexation attending multiple lawsuits, conserve judicial resources, and foster reliance on judicial action by minimizing the possibility of inconsistent decisions.


An antique aircraft enthusiast seeking to restore a vintage airplane manufactured by the Fairchild Engine and Airplane Corporation (FEAC) filed a Freedom of Information Act (FOIA) request asking the Federal Aviation Administration (FAA) for copies of technical documents related to the airplane. The FAA denied his request based on FOIA's exemption for trade secrets. He filed an unsuccessful FOIA lawsuit to secure the documents. Less than a month after that suit was resolved, a friend and fellow antique aircraft enthusiast sought the same vintage airplane technical documents and was also ignored. Thus, he filed suit in the U. S. District Court for the District of Columbia but his case was dismissed because his action was based on claim of preclusion and that he was a "virtual representative” of his friend. On appeal, the Court of Appeals affirmed the district courts decision. The case was elevated on writ of certiorari to the Supreme Court of the United States.


Was the doctrine of claim preclusion properly applied?




The Court disapproved the doctrine of preclusion by "virtual representation" and held that the preclusive effects of a judgment in a federal-question case decided by a federal court should instead be determined according to the established six categories for nonparty preclusion. The court of appeals reached beyond those six categories, and its definition of "adequate representation" strayed from the meaning that the Court attributed to that term. The Court refused to adopt an amorphous balancing test that was at odds with the Court's constrained approach to nonparty preclusion. In considering whether the result reached by the lower courts could be justified based on one of the six established grounds, the Court found that remand was necessary to address the only applicable ground.

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