Preclusion under Civil Procedure
Preclusion in Civil Procedure
1. Introduction
Preclusion is a legal doctrine in civil procedure that prevents parties from relitigating issues or claims that have already been finally decided by a competent court. The main purpose of preclusion is to promote finality, judicial efficiency, and fairness by avoiding repeated lawsuits on the same matters.
2. Types of Preclusion
There are two primary types of preclusion:
Claim Preclusion (Res Judicata)
Issue Preclusion (Collateral Estoppel)
3. Claim Preclusion (Res Judicata)
Definition:
Claim preclusion bars a party from suing on the same cause of action after a final judgment on the merits has been rendered between the same parties or their privies.
Requirements for Claim Preclusion:
Final Judgment on the Merits: The previous case ended with a final decision on substantive issues.
Same Parties or Their Privies: The parties in the current case are the same or closely related to those in the prior case.
Same Cause of Action: The claim or cause of action in the current case was or could have been raised in the prior lawsuit.
Effect:
Once claim preclusion applies, the plaintiff cannot file another lawsuit based on the same claim.
Case Example:
Case: Parklane Hosiery Co. v. Shore
Facts: A company previously sued on securities fraud, and after a final judgment, the plaintiff tried to bring the same claim again.
Holding: The court held that the prior judgment barred the plaintiff from bringing the same claim.
Significance: This case highlights the importance of claim preclusion in preventing repetitive litigation.
4. Issue Preclusion (Collateral Estoppel)
Definition:
Issue preclusion prevents a party from relitigating an issue of fact or law that was already necessarily decided in a prior case.
Requirements for Issue Preclusion:
Identical Issue: The specific issue was actually litigated and decided in the prior case.
Final Judgment: The previous judgment was final and on the merits.
Party Against Whom Preclusion is Sought: The party had a full and fair opportunity to litigate the issue.
Necessity: The issue was essential to the prior judgment.
Effect:
The party cannot contest the issue again in a new lawsuit or proceeding.
Case Example:
Case: Allen v. McCurry
Facts: A party sought to relitigate an issue already decided in a previous suit.
Holding: The court ruled that issue preclusion barred re-examination of the issue.
Significance: This case demonstrates how issue preclusion enforces consistency in judicial decisions.
5. Differences Between Claim Preclusion and Issue Preclusion
| Aspect | Claim Preclusion (Res Judicata) | Issue Preclusion (Collateral Estoppel) |
|---|---|---|
| What is barred? | Entire cause of action | Specific issues previously litigated |
| Scope | Prevents suing the same claim | Prevents relitigating specific facts or legal issues |
| Applies to parties | Same parties or privies | Party against whom issue was decided |
| Timing | After final judgment on the entire case | After final judgment on specific issue |
6. Purpose and Policy Behind Preclusion
Judicial Efficiency: Avoid wasting court resources on the same disputes.
Consistency: Maintain consistency in judicial decisions.
Fairness: Protect parties from harassment by repeated litigation.
7. Summary
| Type | What it Bars | Key Requirements | Case Example |
|---|---|---|---|
| Claim Preclusion | Same claim or cause of action | Final judgment, same parties, same cause | Parklane Hosiery Co. v. Shore |
| Issue Preclusion | Same issue of fact or law | Identical issue, final judgment, fairness | Allen v. McCurry |
8. Conclusion
Preclusion doctrines are fundamental to civil procedure, ensuring that once a dispute or an issue is conclusively resolved, parties cannot rehash it in later proceedings. This promotes fairness, efficiency, and certainty in the legal system.
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