River Park, Inc. v. City of Highland Park (I)

Brief Fact Summary.

River Park, Inc. filed an action in federal district court against the City of Highland Park, alleging that the City intentionally undermined approval of River Park’s property development plans. After the district court dismissed the complaint and the Court of Appeals affirmed the dismissal, River Park filed a state court complaint. The state court dismissed the state court action, holding that River Park’s claims were barred by res judicata. The appellate court reversed, holding that the state court action was not barred by res judicata.

Synopsis of Rule of Law.

For the doctrine of res judicata to apply, there must have been: (1) a final judgment on the merits rendered by a court of competent jurisdiction; (2) identity of the causes of action; and (3) identity of the parties or their privies.

Facts.

River Park, Inc. filed an action in federal district court against the City of Highland Park, alleging that the City intentionally undermined approval of River Park’s property development plans. The federal court complaint alleged that the City violated 42 U.S.C. 1983 by depriving River Park, Inc. of its property rights without due process of law. The Court of Appeals affirmed the the district court’s dismissal of the complaint for failure to allege a violation of due process. River Park then filed a state court complaint against the City which alleged, among other things, tortious interference with business expectancy, breach of implied contract, and abuse of governmental power.  The state court dismissed the action, holding that River Park’s claims were barred under the doctrine of res judicata based on the dismissal of the federal court complaint. The state appellate court reversed, holding that res judicata did not bar the state court action because the causes of action alleged in the complaints were different.

Issue.

Was River Park’s state court action barred by the doctrine of res judicata?

Held.

Yes. The Illinois Supreme Court affirmed the judgment of the lower court, which held that the state court complaint was barred by res judicata.

Discussion.

Thee doctrine of res judicata applied in this case. There  was a final judgment on the merits rendered by a court of competent jurisdiction, and there was identity of the parties or their privies. As to identity of the causes of action, the court adopted the “transactional test,” pursuant to which separate claims are considered the same cause of action for purposes of res judicata if they arise from a single group of operative facts, regardless of whether they assert different theories for relief.