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Taylor v. Sturgell

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Brief Fact Summary.

Plaintiff sued Defendant for not complying with his Freedom of Information Act, a lawsuit nearly identical to one which his friend had just lost.

Synopsis of Rule of Law.

An individual is not bound by a judgment in a lawsuit in which they were not a designated party, made a party by service of process, or adequately represented by a party to the lawsuit.

Points of Law - Legal Principles in this Case for Law Students.

The preclusive effect of a judgment is defined by claim preclusion and issue preclusion, which are collectively referred to as res judicata.

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Facts.

Brent Taylor (Plaintiff), an antique aircraft enthusiast, filed a lawsuit in the U.S. District Court for the District of Columbia after the Federal Aviation Administration (Defendant) refused his Freedom of Information Act request. This lawsuit came one month after Greg Herrick, Plaintiff’s friend, lost a similar lawsuit for a similar request in the U.S. District Court for the District of Wyoming.

Issue.

May a nonparty to a lawsuit be barred by claim preclusion, based on virtual representation?

Held.

No, virtual representation does not allow claim preclusion to bar a nonparty from bringing a similar lawsuit. The lower court’s decision is vacated and the case remanded.

Discussion.

The Court rejected the doctrine of virtual representation as too broad of an exception to the rule that no person can be bound by a judgment to which they were not a party. Virtual representation does not adequately represent the nonparty because it does not guarantee that the party and nonparty interests are aligned, the party knows they are acting in a representative capacity, and notice was given to all nonparties. Finally, the Court determined that the doctrine would increase the burden of litigation on the courts. The Court remanded the case to determine whether the Plaintiff was subject to one of the six grounds for nonparty claim preclusion.


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