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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
Tags: Civil Procedure, Claim Preclusion
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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.
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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.
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