Claim preclusion stops parties from relitigating claims already decided in court. It's a key tool for keeping the legal system efficient and fair, preventing multiple lawsuits on the same issue.

This doctrine is part of the broader concept of preclusion, which aims to limit repeated litigation. Understanding claim preclusion is crucial for grasping how courts manage disputes and ensure finality in legal decisions.

Claim Preclusion: Concept and Purpose

Definition and Legal Basis

• Claim preclusion prevents parties from relitigating claims already adjudicated to final judgment on merits
• Doctrine rooted in Full Faith and Credit Clause of U.S. Constitution
• Recognized in federal and state courts
• Operates as affirmative defense raised by defendant in subsequent litigation

Objectives and Scope

• Promotes judicial efficiency, finality of judgments, and fairness to litigants
• Prevents multiple lawsuits on same claim
• Applies to all claims raised or could have been raised in original action
• Encompasses claims based on different legal theories or seeking different remedies

Elements of Claim Preclusion

Final Judgment Requirements

• Final judgment on merits in prior action
• Rendered by court of competent jurisdiction (subject matter and personal jurisdiction)
• Valid judgment not obtained through fraud, duress, or lack of due process
• Claim in subsequent action must have been ripe for adjudication during prior action

Party and Claim Identity

• Identity of parties or those in privity in both prior and subsequent actions
• Identity of claims between prior and subsequent actions
• Often determined by "transactional test"
• Claim must have been able to be brought in original lawsuit

Effects of Claim Preclusion

Barring Relitigation

• Bars relitigation of entire claim, including all issues raised or could have been raised
• Prevents parties from splitting cause of action
• Extends to all grounds for recovery presentable in first action
• Bars claims sufficiently related to original claim under "transactional test"

Impact on Parties and Claims

• Extinguishes plaintiff's claim entirely, regardless of prior judgment's favorability
• May bind non-parties in privity with original parties (successors in interest, litigation controllers)
• Prevents multiple lawsuits based on same underlying transaction or occurrence

Claim Preclusion vs Issue Preclusion

Scope and Application

• Claim preclusion bars relitigation of entire claim
• Issue preclusion (collateral estoppel) bars relitigation of specific issues actually litigated and necessarily decided
• Claim preclusion applies to all issues that could have been raised
• Issue preclusion only applies to issues actually litigated and essential to judgment

Party Requirements and Usage

• Claim preclusion generally requires mutuality of parties
• Issue preclusion may be used offensively by plaintiff not party to prior action
• Claim preclusion broader in scope but more limited in application to parties
• Issue preclusion narrower in scope but sometimes applicable against non-parties

Policy Goals and Distinctions

• Both serve policy goals of finality and efficiency
• Operate in distinct ways with different application requirements
• Claim preclusion requires identity of claims, issue preclusion does not necessarily require same cause of action