In the vast realm of law, it is imperative to prevent an unwarranted load on the judicial system. To ensure litigants do not burden courts with repetitive and unnecessary cases, various legal doctrines have been established, with one of the most significant being “res judicata.”
Res judicata, derived from the Latin phrase meaning “a matter judged,” aims to prohibit parties from relitigating claims or defenses that have already been decided. The doctrine serves to uphold the finality of judgments and conserve judicial resources, ultimately serving the best interests of the public.
The Three Elements of Res Judicata
Res judicata comprises three main elements: re-litigation, same cause of action, and same or closely related parties.
Res judicata prevents parties from raising a claim in a new lawsuit once that specific claim has been subjected to a final judgment in a previous lawsuit. It is important to note that re-litigation can occur in any court, not solely the one responsible for the initial judgment. This aspect of res judicata is the most straightforward.
Same Cause of Action
Similarly, res judicata bars parties from bringing the same claim or cause of action against a defendant following a final judgment. While “claim” refers to the legal demand for compensation, “cause of action” encompasses the elements allowing for legal remedy.
Same or Closely Related Parties
Determining if a lawsuit involves the same individuals is relatively straightforward when the parties are individuals. However, the principle of res judicata can also prevent litigation brought by parties or entities “in privity” with the original plaintiff or defendant. This includes those “acting as an agent” on behalf of the original plaintiff or any subsidiary of a corporate plaintiff. The same principle applies to defendants.
Res Judicata vs. Collateral Estoppel
Res judicata can be further divided into two major components: res judicata or “claim preclusion” and collateral estoppel, also known as issue preclusion.
Res judicata prohibits the pursuit of a second action on matters previously litigated as a whole, along with claims arising from similar subject matter.
On the other hand, collateral estoppel prevents the re-litigation of specific issues resolved in prior cases. In practice, collateral estoppel acts as the foundation for double jeopardy protections in criminal cases. As established in Benton v. Maryland, this protection is binding in both state and federal courts under the Due Process Clause of the Fourteenth Amendment.
To invoke collateral estoppel, parties must establish several elements:
- The facts in question were fully and fairly litigated.
- The facts were essential to the judgment in the first action.
- The parties were adversarial with respect to that action.
Example of Res Judicata
Res judicata finds broad application in various practical scenarios. The 2018 patent lawsuit, Sowinski v. California Air Resources Board, serves as an illustrative example. In this case, res judicata was found to apply not only to cases resolved on the merits but also to those adjudicated on procedural grounds.
The initial lawsuit occurred in 2015 when Richard Sowinski, the inventor of an electronic method for claiming pollution tax credits, sued the California Air Resources Board (CARB) for allegedly using his patent in one of their programs. The court dismissed the complaint due to Sowinski’s failure to respond to motions within the given deadline.
Sowinski filed a lawsuit again in 2018, seeking infringement damages based on the 2015 case. He argued that res judicata should not apply since the prior suit was dismissed on procedural rather than substantive grounds. However, the U.S. Court of Appeals for the Federal Circuit upheld the lower court’s ruling, applying res judicata regardless, as the cases were essentially the same.
The Value of Res Judicata in Court
Res judicata holds immense value in saving time and resources within the judicial system. In addition, the doctrine aligns with logical reasoning, as it prevents waste and frivolous litigation.
While the phrase “If at first you don’t succeed, try again” may resonate with little leaguers and struggling artists, it does not align well with the realm of attorneys, judges, plaintiffs, and defendants. Hence, res judicata finds significant application in our judicial system.
For further information on relevant and emerging legal doctrines like res judicata, visit Garrity Traina, where we delve into the increasingly applied “Reptile Theory.”