Though courts are busy and judges have overflowing dockets, our justice system requires courts to find time to hear cases worthy of adjudicating. This means that judges must be as efficient as possible. One way of doing this is to require claimants to converge all of their complaints into a single lawsuit. Failure to do this will bar a claimant from bringing a second lawsuit against the same party. This legal theory based in civil procedure is known as res judicata. It seeks to maintain judicial efficiency and protect litigants from facing duplicitous lawsuit from the same claimant. This important principle is important to understand for anyone going forward in a lawsuit because it could prevent a claimant from asserting any material claims against a wrong-doer that were not asserted in the first legal action.
Though courts are assumed to be honest, deceit and bias can seep into the legal fabric. When this occurs, the justice system must reanalyze the applicability of res judicata. One illustrative example of an instance like this took place recently in the United States District Court for the Eastern District of Louisiana. The issue was complicated and was later resolved by the United States Court of Appeals for the Fifth Circuit.
The case in question involved a personal injury lawsuit where a yacht’s boat swells threw another boat into the air and injured a woman in that boat. That injured woman filed suit against the yacht owners and their insurance company. At trial, the judge found for the defendants, essentially stating that the defendant’s expert witness was more reliable than the plaintiff’s expert.
However, during the trial it became apparent that the judge and the defendant’s attorney were good friends. The two had traveled together on hunting trips and the attorney frequently exchanged gifts with the judge. The judge was also friends with the defendant’s expert witness. This led the plaintiff’s to seek the judge’s recusal, which the judge refused to do.
After the trial, the Department of Justice investigated the judge and Congress eventually impeached him. The Plaintiff in the boat swell case then sought a new trial. The Court of Appeals had to determine whether the plaintiff’s claim was barred by res judicata or whether the judge’s bias in the original case allows for a rehearing of the case.
To get around the bar imposed by res judicata, a party can file an independent action in equity. The courts have established five elements that must be met in order to plead a successful independent action in equity: (1) a prior judgment which “in equity and good conscience” should not be enforced; (2) a meritorious claim in the underlying case; (3) fraud, accident, or mistake that prevented the party from prevailing on their claim; (4) the absence of fault or negligence on the part of the party; and (5) the absence of an adequate remedy at law.
This analysis will be continued in the second post on this topic. If you have any questions, please feel free to call our offices.