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Civil Procedure • Collateral Estoppel
CIVPRO#072
Legal Definition
Collateral estoppel binds the plaintiff or defendant (or those in privity with either) in subsequent actions or different causes of action between them regarding issues actually litigated and essential to the judgment in the first action. To bar relitigation of an issue, a party must show: (1) the first case ended in a valid, final judgment on the merits; (2) the issue was actually litigated and determined in the first case; (3) the issue was essential to the judgment; and (4) the second case must be brought by a party or one in privity.
Plain English Explanation
Collateral estoppel is a legal principle that prevents a plaintiff or defendant (and others closely related to them) from re-litigating issues in subsequent actions or different causes of action. This applies specifically to issues that were actually litigated and were essential to the judgment in the first case. Here’s what this means and the criteria needed to establish it:
To bar relitigation of an issue, a party must show:
(1) The first case ended in a valid, final judgment on the merits: This means that the first case was decided by a court and not dismissed for some procedural reason. For example, if someone sued a neighbor for damages from a car accident and the court ruled in favor of the neighbor, that decision is a valid, final judgment.
(2) The issue was actually litigated and determined in the first case: The specific issue in question must have been raised and decided during the trial. Continuing with the previous example, if the issue was whether the neighbor was negligent during the car accident and the court made a decision on that, then it has been "actually litigated."
(3) The issue was essential to the judgment: The issue must be critical to the court's decision in the first case. If the court found the neighbor not liable because they were not negligent, that issue is essential to the judgment.
(4) The second case must be brought by a party or one in privity: This means that the party trying to use collateral estoppel must either be the same party from the first case or someone closely related to that party. For instance, if the injured party tries to sue the neighbor again for the same accident, they can’t reargue the negligence issue since it was already decided in the first case.
To bar relitigation of an issue, a party must show:
(1) The first case ended in a valid, final judgment on the merits: This means that the first case was decided by a court and not dismissed for some procedural reason. For example, if someone sued a neighbor for damages from a car accident and the court ruled in favor of the neighbor, that decision is a valid, final judgment.
(2) The issue was actually litigated and determined in the first case: The specific issue in question must have been raised and decided during the trial. Continuing with the previous example, if the issue was whether the neighbor was negligent during the car accident and the court made a decision on that, then it has been "actually litigated."
(3) The issue was essential to the judgment: The issue must be critical to the court's decision in the first case. If the court found the neighbor not liable because they were not negligent, that issue is essential to the judgment.
(4) The second case must be brought by a party or one in privity: This means that the party trying to use collateral estoppel must either be the same party from the first case or someone closely related to that party. For instance, if the injured party tries to sue the neighbor again for the same accident, they can’t reargue the negligence issue since it was already decided in the first case.
Hypothetical
Hypo 1: Sam is an employee at Amy's Bike Shop and is riding one of the shop's rental bikes through the park as part of his duties to test its safety and functionality. Bob, after having had several beers, drives his car off the road and into the park, hitting Sam on the bike, injuring him, and damaging the bike. Sam sues Bob for his personal injuries, and after thorough litigation, the jury finds that Bob was negligent, awarding damages to Sam. Later, Amy sues Bob for property damage to the bike. In this case, Bob attempts to argue that he was not negligent. Result: Collateral estoppel (issue preclusion) would bar Bob from relitigating the issue of his negligence because the prior case already established it. Here, privity exists between Sam and Amy because Sam was acting within the scope of his employment for Amy's Bike Shop when the accident occurred. Going through the elements:
(1) Sam’s case resulted in a valid, final judgment on the merits;
(2) The issue of Bob’s negligence was actually litigated and determined against him;
(3) The issue of negligence was essential to the judgment in Sam’s case;
(4) Privity exists between Sam and Amy due to Sam’s role as an employee acting on behalf of Amy's Bike Shop when the incident occurred.
Note: In this scenario, privity between Sam and Amy allows Amy to invoke issue preclusion against Bob because Sam’s litigation efforts were directly related to his duties for Amy’s business.
(1) Sam’s case resulted in a valid, final judgment on the merits;
(2) The issue of Bob’s negligence was actually litigated and determined against him;
(3) The issue of negligence was essential to the judgment in Sam’s case;
(4) Privity exists between Sam and Amy due to Sam’s role as an employee acting on behalf of Amy's Bike Shop when the incident occurred.
Note: In this scenario, privity between Sam and Amy allows Amy to invoke issue preclusion against Bob because Sam’s litigation efforts were directly related to his duties for Amy’s business.
