Taylor v. Sturgell

Brief Fact Summary.

Plaintiff filed a lawsuit in federal district court that was based on a similar claim that had been unsuccessfully litigated by his friend.

Synopsis of Rule of Law.

A claim is not precluded from being litigated if the previous litigant had no legal relationship with the past litigant.

Facts.

Taylor (plaintiff) filed a lawsuit in federal district court under the Freedom of Information Act against the Fairchild Engine and Airplane Corporation (hereinafter “Fairchild”) and the FAA (defendants), seeking documents on an airplane manufactured by the Fairchild. Taylor’s friend Herrick had previously filed an unsuccessful lawsuit seeking the same information. The district court held that Taylor’s lawsuit was barred by the judgment against Herrick since Taylor’s interests had been virtually represented by Herrick. Taylor appealed.

Issue.

Whether plaintiff could litigate the same claim as that which had been previously litigated by his friend?

Held.

Yes. No legal relationship existed between Taylor and Herrick, so claim preclusion does not apply. The judgment of the United States Court of Appeals for the District of Columbia is vacated and the case is remanded fo further proceedings.

Discussion.

A litigant may be subject to claim preclusion if that litigant has been adequately represented by the previous party and either: (1) the court uses “special procedures to protect the nonparties’ interests” or (2) “an understanding by the concerned parties that the first suit was brought in a representative capacity.” Some courts have recognized a “virtual representation” exception to the rule against claim preclusion. The Supreme Court, however, rejects the doctrine of preclusion by virtual representation for three reasons. First, the Court recognizes the general rule that a party is not bound by a judgment to which he or she was not a party. Second, the virtual representation doctrine would hold a party responsible for a suit for which they were not noticed. Third, recognition of this doctrine would significantly drain court resources. Here, Taylor did not know of Herrick’s initial lawsuit nor did Herrick take special care of Taylor’s interests in the initial lawsuit. Herrick’s representation was not adequate. No legal relationship existed between Taylor and Herrick, so claim preclusion does not apply.