Rodgers v. St. Mary’s Hospital

Brief Fact Summary.

Rodgers filed two separate suits against St. Mary’s Hospital, claiming wrongful death and failure to preserve x-rays, for their contribution to his wife’s death.

Synopsis of Rule of Law.

Two claims are the same under res judicata if the same facts are essential to both claims and the claims arise out of the same transaction or occurrence.

Facts.

Rodgers commenced a wrongful death suit against St. Mary’s hospital for his wife’s death as a result of medical malpractice. Rodgers claimed that his wife’s condition was apparent in an x-ray that was lost, and summary judgment was subsequently granted to the hospital. Rodgers then sued the hospital for failing to preserve his wife’s x-ray for five years, causing a loss of evidence. The trial court dismissed and Rodgers appealed. The appellate court reversed.

Issue.

Whether two claims are the same under res judicata if the same facts are not essential to both claims and the claims do not arise out of the same transaction or occurrence?

Held.

No. The judgment of the appellate court is affirmed. Rodger’s suit is not barred by res judicata because his medical malpractice claim is not the same as his loss of evidence claim. Loss of evidence claims require different evidence and facts to overcome in the case, and the two claims did not arise out of the same transaction or occurrence, as the x-ray files were lost after the death of Rodger’s wife.

Discussion.

Two claims are the same under res judicata if the same facts are essential to both claims and the claims arise out of the same transaction or occurrence. Res Judicata prevents a party from relitigating the same claims after being issued a final judgment from a court with jurisdiction.