Warning

Info

Table of Contents
Pilea, HLS '24 |

0 0

Back to briefs

Taylor v. Sturgell

(2008)

Supreme Court of the United States - 553 U.S. 880, 128 S.Ct. 2161, 171 L.Ed.2d 155, 553 U.S. 880, 171 L. Ed. 2d 155, 128 S. Ct. 2161, SCDB 2007-055, 2008 U.S. LEXIS 4885

tl;dr:

This case demonstrates an exception to the mutuality of claim preclusion.

Video Summary


Case Summary

In the case of Taylor v. Sturgell (2008), the Supreme Court overturned a Court of Appeals ruling that supported a summary judgment awarded to the Federal Aviation Administration (FAA) and Fairchild Corporation due to claim preclusion. Brent Taylor, the plaintiff and an antique aircraft enthusiast, wanted to get plans for a rare airplane engine from the FAA through a Freedom of Information Act (FOIA) request. The FAA had already denied a similar request from Taylor's friend, Greg Herrick, who had previously sued the FAA and lost.

The FAA and Fairchild argued that Taylor's lawsuit was blocked by claim preclusion since Herrick virtually represented Taylor in the earlier case. The significance of this case is that it clarifies the doctrine of res judicata and narrows the situations in which a nonparty can be affected by a prior judgment.

The Court determined that nonparty preclusion is only suitable in six types of cases, such as when the nonparty agrees to be bound by the previous judgment or when a substantive legal relationship already exists between the nonparty and someone involved in the prior judgment. The Court rejected the concept of "virtual representation" as being too vague and not aligned with due process. The case was sent back for further proceedings to establish if Taylor acted as an agent or proxy for Herrick.

ICRAIssue, Conclusion, Rule, Analysis for Taylor v. Sturgell

LSD+ exclusive

This content is exclusively for LSD+ users.

Sign up for LSD+ for full access to the Taylor v. Sturgell case brief summary.

Enjoy unlimited access with our 14-day free trial.

Facts & HoldingTaylor v. Sturgell case brief facts & holding

Facts:Taylor unsuccessfully sought information via the Freedom of Information Act...

Holding:Taylor may litigate his own claim, because he does not...

LSD+ exclusive

This content is exclusively for LSD+ users.

Sign up for LSD+ for full access to the Taylor v. Sturgell case brief summary.

Enjoy unlimited access with our 14-day free trial.

DeepDiveHighlight a legal term to see the definition

Font size -+
Taylor v. Sturgell | Case Brief DeepDive
Majority opinion, author: Justice Ginsburg
Level 1
Click below 👇 to DeepDive

The legal case involves Brent Taylor's FOIA request for documents from the FAA, which was initially denied due to a previous unsuccessful lawsuit by his friend, Greg Herrick. The D.C. Circuit found that Taylor's suit was not barred by claim preclusion because of Herrick's previous lawsuit, and announced its own five-factor test for virtual representation. The D.C. Circuit's definition of "adequate representation" strayed from the meaning attributed to that term by the Supreme Court. The application of claim preclusion was inconsistent with due process of law guaranteed by the Fourteenth Amendment when absent parties were not protected or understood to be represented in the first suit. The Supreme Court's decisions recognizing that a nonparty may be bound by a judgment if adequately represented by a party to the earlier suit do not support the D.C. Circuit's broad theory of virtual representation.

Lorem ipsum dolor sit amet, consectetur adipiscing elit, sed do eiusmod tempor incididunt ut labore et dolore magna aliqua.Lorem ipsum dolor sit amet, consectetur adipiscing elit, sed do eiusmod tempor incididunt ut labore et dolore magna aliqua.Lorem ipsum dolor sit amet, consectetur adipiscing elit, sed do eiusmod tempor incididunt ut labore et dolore magna aliqua.Lorem ipsum dolor sit amet, consectetur adipiscing elit, sed do eiusmod tempor incididunt ut labore et dolore magna aliqua.Lorem ipsum dolor sit amet, consectetur adipiscing elit, sed do eiusmod tempor incididunt ut labore et dolore magna aliqua.Lorem ipsum dolor sit amet, consectetur adipiscing elit, sed do eiusmod tempor incididunt ut labore et dolore magna aliqua.

LSD+ exclusive

This content is exclusively for LSD+ users.

Sign up for LSD+ for full access to the Taylor v. Sturgell case brief summary.

Enjoy unlimited access with our 14-day free trial.

🤯 High points 🤯Key points contributed by students on LSD

LSD+ exclusive

This content is exclusively for LSD+ users.

Sign up for LSD+ for full access to the Taylor v. Sturgell case brief summary.

Enjoy unlimited access with our 14-day free trial.

LSD+ Case Briefs

Features

  • DeepDive for detailed case analysis
  • Over 50,000 existing case briefs
  • Instant briefs for another 6,000,000 cases
  • Highlight dictionary for legal term definitions
  • Social learning with chat and high points

Over 50,000 Cases Briefed

LSD+ gives you access to over 50,000 case briefs, more than anyone else. Be the first to email us the website of a case brief product that offers you more case briefs and we'll give you a free year of LSD+.

14-Day Free Trial

Unlimited access. Read as much content as you want during your trial with no device limitations. Cancel any time during your trial and keep access for the full 14 days.

Integrated Legal Dictionary

Lawyers and judges love to use big words. And Latin, for some reason.

Highlight a legal term in LSD Briefs and get an instant, plain English definition. Try highlighting contract or specific performance. No need to search or read through a list of definitions, simply highlight the words you don’t know and our LSDefine integration will instantly give you a definition to any of over 30,000 legal terms.

DeepDive

DeepDive allows you to explore legal cases like never before. DeepDive offers multiple levels of case summaries, which empowers you to quickly and easily find the information you need to stay on top of readings. Easily navigate through summary levels and click on any text to get more detail, all the way down to the original legal case text.

Brief anything. Instantly.

Our proprietary state-of-the-art system can instantly brief over 6,000,000 US cases. That means we can probably brief that case that your professor assigned last night when she sent you a poorly scanned pdf and told you to read every third paragraph. Or maybe she uploaded it to Canvas and didn’t really tell you to read it, but you know you probably should. Tenure does wild things to good people.

Social Learning with Chat and High Points

Study groups are a great way to learn and explore a case. LSD has chat rooms for each case to let you ask questions across the community and hear what other students struggled with and how they put it all together. Learn the key points of every case from other LSD+ users and share your knowledge with LSD High Points.

Real-Time Brief Feedback

Don’t settle for mistakes in briefs that have been there for 10 years and never fixed. Find an issue or something missing from a brief? Down vote and we will make improvements. All of our case brief editors graduated from from T14 law schools.

Taylor v. Sturgell

Chat for Taylor v. Sturgell
brief-319
👍 Chat vibe: 0 👎
Help us make LSD better!
Tell us what's important to you
LSD+ is ad-free, with DMs, discounts, case briefs & more.