In general, a judgment is res judicata not only as to all matters litigated and decided by it, but also as to all relevant issues which could have been, but were not, raised and litigated in the suit. P. 327 U. S. 735. U.S. Supreme Court Heiser v. Woodruff, 327 U.S. 726 (1946) No. 496. Argued March 5, 1946 Decided April 22, 1946
The fundamental doctrine of res judicata rests at the core of our judicial system… the fundamental doctrine of res judicata is the constitutional mandate that all courts in the United States must give full faith and credit to the decisions of other courts, be they territorial, state, federal, or special tribunals. U.S. Const. art. IV, § 1. Again, the full faith and credit principle furthers the goals of certainty, finality, and comity in legal dealings within our nation… Res judicata is a "general and well-established doctrine . . . conceived in the light of the maxim that the interest of the state requires that there be an end to litigation a maxim which comports with common sense as well as public policy." Federated Department Stores, Inc. v. Moitie, 452 U.S. 394, 401, 101 S. Ct. 2424, 2429, 69 L. Ed. 2d 103 (1981) (quoting Reed v. Allen, 286 U.S. 191, 198-99, 52 S. Ct. 532, 533, 76 L. Ed. 1054 (1932)). In the Matter of Adrian Bonilla MONTALVO, Debtor. Adrian Bonilla MONTALVO, Plaintiff-Appellant, v. BANCO COMERCIAL DE MAYAGUEZ; Neftali Rosa; Eugenio Rivera; Dagoberto Montalvo Ignacio; Neca Mortgage Corp.; Eddie Acaron, and Frank Ramirez Ramirez, Defendants-Appellees. Civ. No. 92-2333 (JAF), Bankruptcy No. 87-00304 (SEK), Adv. No. 89-0029. United States District Court, D. Puerto Rico. July 8, 1993.
Res Judicata is a principle or maxim in law that deals with cases already adjudicated and said cases, either quotes or the case itself is then used for substantiating the accuser or defendants proof of claim; expression of pre-existing rights, constitutional enforcement, the adherence to due process, or commanding the courts to act on a matter, make a decision or issue a judgment or decree in your favor, et alia.
Res judicata (RJ) or res iudicata, also known as claim preclusion, is the Latin term for "a matter [already] judged", and refers to either of two concepts: in both civil law and common law legal systems, a case in which there has been a final judgment and is no longer subject to appeal; and the legal doctrine meant to bar (or preclude) continued litigation of a case on same issues between the same parties. In this latter usage, the term is synonymous with "issue preclusion". In the case of res judicata, the matter cannot be raised again, either in the same court or in a different court. A court will use res judicata to deny reconsideration of a matter.
The doctrine of res judicata is a method of preventing injustice to the parties of a case supposedly finished, but perhaps also or mostly a way of avoiding unnecessary waste of resources in the court system. Res judicata does not merely prevent future judgments from contradicting earlier ones, but also prevents litigants from multiplying judgments, and confusion. Res judicata includes two related concepts: claim preclusion and issue preclusion (also called collateral estoppel or issue estoppel), though sometimes res judicata is used more narrowly to mean only claim preclusion.
Claim preclusion bars a suit from being brought again on an event which was the subject of a previous legal cause of action that has already been finally decided between the parties or those in privity with a party. Issue preclusion bars the re-litigation of issues of fact or law that have already been necessarily determined by a judge or jury as part of an earlier case. Res judicata is intended to strike a balance between competing interests. Its primary purpose is to assure an efficient judicial system. A related purpose is to create "repose" and finality.
Justice Stewart explained the need for this legal precept as follows:
Federal courts have traditionally adhered to the related doctrines of res judicata (claim preclusion) and collateral estoppel (issue preclusion). Under RJ, a final judgment on the merits of an action precludes the parties . . . from re-litigating issues that were or could have been raised in that action. Under collateral estoppel, once a court has decided an issue of fact or law necessary to its judgment, that decision may preclude re-litigation of the issue in a suit on a different cause of action involving a party to the first cause. As this court and other courts have often recognized, res judicata and collateral estoppel relieve parties of the costs and vexation of multiple lawsuits, conserve judicial resources, and by preventing inconsistent decisions, encourage reliance on adjudication.
Abbott Laboratories v Granite State INS. CO. 573 F Supp 193. Crosskey, politics and the constitution in the history of the united states ch XXVI, and particularly at 916-19 ff (1953). As professor Crosskey has also pointed out (id at ch XX - XXI) under a reading that the term “Laws” include the “common law” as well as legislation… a federal decision on any substantive common law question would then become binding on all state courts. Failure or refusal of a state court to follow that decision would then pose the federal question.
United States Supreme Court – Durfee v Duke 375 U.S. 106. The constitutional command of full faith and credit, as implemented by congress, generally requires every state to give to a judgement at least the res judicata effect which the judgement would be accorded in the state which rendered it… res judicata [is] part of national jurisprudence… The principles of res judicata apply to questions of jurisdiction as well as to other issues, as well to jurisdiction of the subject-matter as of the parties.
Massachusetts Supreme Judicial Court – Bagley v Moxley 407 Mass 633. "`Res judicata' is the generic term for various doctrines by which a judgment in one action has a binding effect in another." Heacock v. Heacock, 402 Mass. 21, 23 n. 2 (1988). This court has recognized that "[t]he doctrine of res judicata . . . [is] most important in assuring that judgments are conclusive, thus avoiding relitigation of issues that were or could have been raised in the original action." Anderson v. Phoenix Inv. Counsel of Boston, Inc., 387 Mass. 444, 449 (1982). Application of the doctrine may serve to "relieve parties of the cost and vexation of multiple lawsuits, conserve judicial resources, and, by preventing inconsistent decisions, encourage reliance on adjudication." Id., quoting Allen v. McCurry, 449 U.S. 90, 94 (1980).
Massachusetts Supreme Judicial Court – Alicea v Commonwealth 466 Mass 228, 234 99 N.E. 2d 725. Whether federal court judgement or order has preclusive effect in state court proceeding is governed by federal common law not by state law… whether a previous decision is to be given preclusive effect presents a question of law appropriate for resolution on summary judgement… The preclusive effect of a federal court judgement is governed by federal common law. Under federal common law, the doctrines of claim preclusion and issue preclusion (collectively res judicata) define the preclusive effect of a prior judgement… Together, claim preclusion and issue preclusion promote judicial economy and comity between the state and federal courts, prevent the cost and aggravation of additional litigation, and encourage reliance on prior adjudications… under the doctrine of claim preclusion, a final judgement forecloses successive litigation of the very same claim, whether or not relitigating of the same claim raises the same issue as the earlier suit. Issue preclusion, in contrast bars successive litigation of an issue of fact of law actually litigated and resolved in a valid court determined essential to the prior judgement, even if the issue recurs in the context of a different claim. Together, claim preclusion and issue preclusion relieve parties of the cost and vexation of multiple lawsuits, conserve judicial resources, and, by preventing inconsistent decisions, encourages reliance on adjudication… federal courts participate in developing uniform federal rules of res judicata, which the united states supreme court has ultimate authority to determine and declare.
The fundamental doctrine of res judicata rests at the core of our judicial system… the fundamental doctrine of res judicata is the constitutional mandate that all courts in the United States must give full faith and credit to the decisions of other courts, be they territorial, state, federal, or special tribunals. U.S. Const. art. IV, § 1. Again, the full faith and credit principle furthers the goals of certainty, finality, and comity in legal dealings within our nation… Res judicata is a "general and well-established doctrine . . . conceived in the light of the maxim that the interest of the state requires that there be an end to litigation a maxim which comports with common sense as well as public policy." Federated Department Stores, Inc. v. Moitie, 452 U.S. 394, 401, 101 S. Ct. 2424, 2429, 69 L. Ed. 2d 103 (1981) (quoting Reed v. Allen, 286 U.S. 191, 198-99, 52 S. Ct. 532, 533, 76 L. Ed. 1054 (1932)). In the Matter of Adrian Bonilla MONTALVO, Debtor. Adrian Bonilla MONTALVO, Plaintiff-Appellant, v. BANCO COMERCIAL DE MAYAGUEZ; Neftali Rosa; Eugenio Rivera; Dagoberto Montalvo Ignacio; Neca Mortgage Corp.; Eddie Acaron, and Frank Ramirez Ramirez, Defendants-Appellees. Civ. No. 92-2333 (JAF), Bankruptcy No. 87-00304 (SEK), Adv. No. 89-0029. United States District Court, D. Puerto Rico. July 8, 1993.
Res Judicata is a principle or maxim in law that deals with cases already adjudicated and said cases, either quotes or the case itself is then used for substantiating the accuser or defendants proof of claim; expression of pre-existing rights, constitutional enforcement, the adherence to due process, or commanding the courts to act on a matter, make a decision or issue a judgment or decree in your favor, et alia.
Res judicata (RJ) or res iudicata, also known as claim preclusion, is the Latin term for "a matter [already] judged", and refers to either of two concepts: in both civil law and common law legal systems, a case in which there has been a final judgment and is no longer subject to appeal; and the legal doctrine meant to bar (or preclude) continued litigation of a case on same issues between the same parties. In this latter usage, the term is synonymous with "issue preclusion". In the case of res judicata, the matter cannot be raised again, either in the same court or in a different court. A court will use res judicata to deny reconsideration of a matter.
The doctrine of res judicata is a method of preventing injustice to the parties of a case supposedly finished, but perhaps also or mostly a way of avoiding unnecessary waste of resources in the court system. Res judicata does not merely prevent future judgments from contradicting earlier ones, but also prevents litigants from multiplying judgments, and confusion. Res judicata includes two related concepts: claim preclusion and issue preclusion (also called collateral estoppel or issue estoppel), though sometimes res judicata is used more narrowly to mean only claim preclusion.
Claim preclusion bars a suit from being brought again on an event which was the subject of a previous legal cause of action that has already been finally decided between the parties or those in privity with a party. Issue preclusion bars the re-litigation of issues of fact or law that have already been necessarily determined by a judge or jury as part of an earlier case. Res judicata is intended to strike a balance between competing interests. Its primary purpose is to assure an efficient judicial system. A related purpose is to create "repose" and finality.
Justice Stewart explained the need for this legal precept as follows:
Federal courts have traditionally adhered to the related doctrines of res judicata (claim preclusion) and collateral estoppel (issue preclusion). Under RJ, a final judgment on the merits of an action precludes the parties . . . from re-litigating issues that were or could have been raised in that action. Under collateral estoppel, once a court has decided an issue of fact or law necessary to its judgment, that decision may preclude re-litigation of the issue in a suit on a different cause of action involving a party to the first cause. As this court and other courts have often recognized, res judicata and collateral estoppel relieve parties of the costs and vexation of multiple lawsuits, conserve judicial resources, and by preventing inconsistent decisions, encourage reliance on adjudication.
Abbott Laboratories v Granite State INS. CO. 573 F Supp 193. Crosskey, politics and the constitution in the history of the united states ch XXVI, and particularly at 916-19 ff (1953). As professor Crosskey has also pointed out (id at ch XX - XXI) under a reading that the term “Laws” include the “common law” as well as legislation… a federal decision on any substantive common law question would then become binding on all state courts. Failure or refusal of a state court to follow that decision would then pose the federal question.
United States Supreme Court – Durfee v Duke 375 U.S. 106. The constitutional command of full faith and credit, as implemented by congress, generally requires every state to give to a judgement at least the res judicata effect which the judgement would be accorded in the state which rendered it… res judicata [is] part of national jurisprudence… The principles of res judicata apply to questions of jurisdiction as well as to other issues, as well to jurisdiction of the subject-matter as of the parties.
Massachusetts Supreme Judicial Court – Bagley v Moxley 407 Mass 633. "`Res judicata' is the generic term for various doctrines by which a judgment in one action has a binding effect in another." Heacock v. Heacock, 402 Mass. 21, 23 n. 2 (1988). This court has recognized that "[t]he doctrine of res judicata . . . [is] most important in assuring that judgments are conclusive, thus avoiding relitigation of issues that were or could have been raised in the original action." Anderson v. Phoenix Inv. Counsel of Boston, Inc., 387 Mass. 444, 449 (1982). Application of the doctrine may serve to "relieve parties of the cost and vexation of multiple lawsuits, conserve judicial resources, and, by preventing inconsistent decisions, encourage reliance on adjudication." Id., quoting Allen v. McCurry, 449 U.S. 90, 94 (1980).
Massachusetts Supreme Judicial Court – Alicea v Commonwealth 466 Mass 228, 234 99 N.E. 2d 725. Whether federal court judgement or order has preclusive effect in state court proceeding is governed by federal common law not by state law… whether a previous decision is to be given preclusive effect presents a question of law appropriate for resolution on summary judgement… The preclusive effect of a federal court judgement is governed by federal common law. Under federal common law, the doctrines of claim preclusion and issue preclusion (collectively res judicata) define the preclusive effect of a prior judgement… Together, claim preclusion and issue preclusion promote judicial economy and comity between the state and federal courts, prevent the cost and aggravation of additional litigation, and encourage reliance on prior adjudications… under the doctrine of claim preclusion, a final judgement forecloses successive litigation of the very same claim, whether or not relitigating of the same claim raises the same issue as the earlier suit. Issue preclusion, in contrast bars successive litigation of an issue of fact of law actually litigated and resolved in a valid court determined essential to the prior judgement, even if the issue recurs in the context of a different claim. Together, claim preclusion and issue preclusion relieve parties of the cost and vexation of multiple lawsuits, conserve judicial resources, and, by preventing inconsistent decisions, encourages reliance on adjudication… federal courts participate in developing uniform federal rules of res judicata, which the united states supreme court has ultimate authority to determine and declare.