Cambria v. Jeffery

Brief Fact Summary.

J and C got into a car accident. J sued C for negligence to recover money damages. The judge ruled that both were negligent and ruled in favor of C. Then, C sued J for negligence to recover money damages, and the jury returned a verdict in favor of C.

Synopsis of Rule of Law.

A fact in a case is adjudicated only when it is material to the judgment in order for the doctrine of issue preclusion to apply.

Facts.

Defendant Jeffery (Jeffery) and Plaintiff Cambria’s servant (Cambria) got into a car accident. In a prior lawsuit, Jeffery sued Cambria in a district court for negligence as he sustained bodily injury and damage to his car. The judge ruled that both parties were at fault; as such, judgment was entered in favor of Cambria. Afterwards, Cambria sued Jeffery for negligence for damage to Cambria’s car. The jury ruled in favor of Cambria for $838.53. However, the judge entered a verdict for Jeffery because the earlier judgment had adjudicated that both parties were negligent.

Issue.

Does the doctrine of issue preclusion prohibit the litigation of a fact that was not material to the ruling?

Held.

No. The doctrine of issue preclusion only prohibits those facts that are material to the ruling. In this case, the earlier ruling was that Jeffery could not recover against Cambria based solely on Jeffery’s contributory negligence. The finding that Cambria was also negligent did not have any effect on coming to that conclusion. Therefore, the judge’s ruling that Cambria was also negligent was not adjudicated. As such, the judge’s verdict is set aside, while the jury’s verdict in favor of Cambria was entered.

Discussion.

The doctrine of issue preclusion only bars facts from being relitigated when those facts have been adjudicated in a prior lawsuit. In order for a fact to be considered adjudicated in a prior lawsuit, that fact must have been material to the judgment. Even though the judge addressed the fact that Cambria was negligent, that fact did not matter with respect to the doctrine of contributory negligence. Under the doctrine of contributory negligence, a party who is considered negligent will not recover regardless of whether the other party is negligent.