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Legal Memorandum: Res Judicata and Collateral Estoppel in MN

Issue: Under Minnesota law, what are the general principles of res judicata and collateral estoppel?

Area of Law: Litigation & Procedure
Keywords: Res judicata and collateral estoppel; General principles
Jurisdiction: Minnesota
Cited Cases: 732 N.W.2d 209
Cited Statutes: Federal Rule 56; 95 A.L.R.2d 648
Date: 00/01/2008

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. 

Brown-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).  Res judicata applies equally to claims that were actually litigated and to claims that could have been litigated in the earlier action.  Brown-Wilbert, 732 N.W.2d at 220.  Whether res judicata applies in a particular case is a question of law, which means it should be answerable by the court on a motion for summary judgment.  See Hauschildt, 686 N.W.2d at 840.  Indeed, a motion for summary judgment is an appropriate vehicle to raise the bar of res judicata or collateral estoppel.  See generally J.C. Vance, Annotation, Raising Res Judicata by Motion for Summary Judgment Under Federal Rule 56 and Similar State Statutes or Rules, 95 A.L.R.2d 648 (1964 & Supp. 2008).  

Collateral estoppel is related to res judicata, although the latter, also deemed “claim preclusion,” is broader than collateral estoppel—or “issue preclusion”—and applies more generally to a set of circumstances that give rise to entire claims or lawsuits.  Hauschildt, 686 N.W.2d […]

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