In the Eleventh Circuit, What Are the Common Law Principles for Claim Preclusion and Issue Preclusion (Res Judicata)?

A judgment’s preclusive effect is defined by claim preclusion and issue preclusion, which are collectively referred to as “res judicata.” Taylor v. Sturgell, 553 U.S. 880, 892 (2008). “Under the doctrine of claim preclusion, a final judgment forecloses successive litigation of the very same claim, whether or not relitigation of the claim raises the same issues as the earlier suit.” Id. (quoting New Hampshire v. Maine, 553 U.S. 742, 748 (2001)). In comparison, issue preclusion “bars successive litigation of an issue of fact or law actually litigated and resolved in a valid court determination essential to the prior judgment, even if the issue recurs in the context of a different claim.” Id. (quoting New Hampshire, 532 U.S. at 748–49).

The doctrine of res judicata bars subsequent litigation where four elements are met: (1) the prior decision was rendered by a court of competent jurisdiction; (2) there was a final judgment on the merits; (3) the parties were identical in both suits; and (4) the prior and present causes of action are the same. Lobo v. Celebrity Cruises, Inc., 704 F.3d 882, 892 (11th Cir. 2013). Eleventh Circuit precedent explains that claims are part of the same cause of action when they “arise out of the same transaction or series of transactions.” Trustmark Ins. Co. v. ESLU, Inc., 299 F.3d 1265, 1269–70 (11th Cir. 2002) (citation omitted). To determine whether the prior and present causes of action are “the same” for purposes of res judicata, the court’s analysis centers on whether the actions arise “out of the same nucleus of operative fact or are based on the same factual predicate.” Davila v. Delta Air Lines, Inc., 326 F.3d 1183, 1187 (11th Cir. 2003); see also Trustmark, 299 F.3d at 1271 (“Res judicata bars the filing of claims which were raised or could have been raised in an earlier proceeding.”). Claims that could have been raised are claims in existence at the time the original complaint is filed. Ragsdale v. Rubbermaid, Inc., 193 F.3d 1235, 1240 (11th Cir. 1999).

Joel Ewusiak frequently represents parties in U.S. District Courts located within the Eleventh Circuit, including in the U.S. District Court for the Middle District of Florida. Please contact Joel for legal assistance with your specific matter.