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Legal Memorandum: Doctrine of Res Judicata in MN

Issue: Under Minnesota law, how is the doctrine of res judicata applied?

Area of Law: Litigation & Procedure
Keywords: Doctrine of res judicata; Relitigating a cause of action; Judgment on the merits
Jurisdiction: Minnesota
Cited Cases: 124 N.W.2d 328; 155 Minn. 388; 266 Minn. 450; 193 N.W. 687; 686 N.W.2d 829; 423 N.W.2d 686; 412 N.W.2d 5
Cited Statutes: None
Date: 12/01/2010

The doctrine of res judicata precludes a party from relitigating a cause of action in a second lawsuit if:

(1)               the earlier claim involved the same set of factual circumstances;

(2)               it involved the same parties or their privies;

(3)               there was a final judgment on the merits; and

(4)               the party against whom the doctrine is asserted had a full and fair opportunity to litigate the matter.  The Debtor-Wilbert, Inc. v. Copeland Buhl & Co., 732 N.W.2d 209, 220 (Minn. 2007); Hauschildt v. Beckingham, 686 N.W.2d 829, 840 (Minn. 2004).  Importantly, res judicata applies equally to claims that were actually litigated and to claims that could have been litigated in the earlier action.  The Debtor-Wilbert, 732 N.W.2d at 220; Hofstad v. Hargest, 412 N.W.2d 5, 7-8 (Minn. Ct. App. 1987); see also Youngstown Mines Corp. v. Prout, 266 Minn. 450, 124 N.W.2d 328, 340 (1963) (stating that “[a] judgment on the merits constitutes an absolute bar to a second suit for the same cause of action, and is conclusive between parties and privies, not only as to every matter which was actually litigated, but also as to every matter which might have been litigated therein.”). 

Under that doctrine, once a plaintiff wins a judgment, the judgment extinguishes the original cause of action, including all of the claims that the plaintiff “could have raised in relation to the transaction out of […]

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