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Civil Procedure • Res Judicata
CIVPRO#069
Legal Definition
Res judicata bars an entire case once a final judgment on the merits has been rendered on a particular cause of action. To successfully bar a claim, the proponent must show: (1) the earlier judgment was a valid, final judgment on the merits; (2) the same cause of action is involved in the later lawsuit; (3) the later lawsuite involves the same parties or their privies as the earlier action; and (4) the cause of action was litigated or could have been litigated in the prior action.
Plain English Explanation
"Res Judicata" is Latin for "A Matter Judged." It means that a matter has already been figured out and settled by a court, and the parties to that matter are not allowed to waste another court's time with trying to have it heard again. Here's a short summary of what's needed for it:
1. Earlier Judgment: earlier final, valid judgment on merits
2. Same Parties: same claimant against same ∆
3. Same claim: same cause of action
4. Chance to Litigate: cause of action litigated or could have been litigated previously.
1. Earlier Judgment: earlier final, valid judgment on merits
2. Same Parties: same claimant against same ∆
3. Same claim: same cause of action
4. Chance to Litigate: cause of action litigated or could have been litigated previously.
Hypothetical
Hypo 1: Sam is riding his bike one day when Bob, who is driving his car, hits Sam in a crosswalk. Sam sues Bob for his personal injuries and receives a judgment against Bob. Days later, after the judgment is entered, Sam realizes he never sued Bob for the damages to his bike, so he attempts to sue Bob again. Result: Res judicata applies and Sam is barred from bringing his claim. Here, the earlier judgment against Bob was valid on the merits, the new case involves the same parties (Sam vs. Bob), Sam is also suing for the same cause of action (Bob hitting him with his car), and Sam already had a chance to litigate the issue of property damage while he was pursuing his physical injuries. In other words, it would be unfair to allow Sam to keep bringing Bob to court to nit-pick every nuanced claim, over and over again, when it should have all been grouped together in one use of the court system.
Hypo 2:* Same facts as *Hypo 1*, except now Bob brings a claim against Sam for damages to his car, but this time, Bob is alleging a separate incident that occurred weeks later at a different intersection. In this new incident, Bob claims that Sam negligently collided with his car while crossing on his bike. Result: Res judicata does not apply, because this lawsuit involves a different cause of action stemming from a separate incident. Although the parties are the same (Bob vs. Sam), the claims arise from distinct events and separate injuries. Therefore, each incident constitutes a unique cause of action, allowing Bob to bring a new claim against Sam without being barred by res judicata.
Hypo 2:* Same facts as *Hypo 1*, except now Bob brings a claim against Sam for damages to his car, but this time, Bob is alleging a separate incident that occurred weeks later at a different intersection. In this new incident, Bob claims that Sam negligently collided with his car while crossing on his bike. Result: Res judicata does not apply, because this lawsuit involves a different cause of action stemming from a separate incident. Although the parties are the same (Bob vs. Sam), the claims arise from distinct events and separate injuries. Therefore, each incident constitutes a unique cause of action, allowing Bob to bring a new claim against Sam without being barred by res judicata.
