Taylor v. Sturgell, 553 U.S. 880 (2008)
Primary Holding
The Supreme Court disapproved the doctrine of preclusion by "virtual representation," holding that a judgment against one party does not bar a nonparty from maintaining a separate suit unless the nonparty was adequately represented in the prior litigation.
In the case of Taylor v. Sturgell, the Supreme Court decided that if someone loses a lawsuit, that loss doesn't automatically prevent another person from filing a similar lawsuit, unless the second person was properly involved in the first case. This is important for consumers because it means you can pursue your own legal rights without being unfairly blocked by someone else's case that you weren't part of. This ruling is relevant if you want to file a lawsuit but are worried that a previous case involving a different person might affect your ability to do so.
AI-generated plain-language summary to help you understand this case
Herrick sought the plans and specifications for a rare aircraft from the FAA, and he filed a Freedom of Information Act (FOIA) request. Asserting that this information was a protected trade secret, the FAA refused to release it to Herrick. He brought an action to recover the plans but failed in the lower federal courts. Herrick's attorney then assisted Taylor in submitting another FOIA request for the plans, which was also denied. When Taylor filed a similar action in federal court to the actions previously brought by Herrick, the court ruled that it could not hear the case because Taylor had been virtually represented by Herrick in the earlier action. On appeal, Taylor asserted that several other federal appellate courts used a different test to determine whether virtual representation applied.
Whether the doctrine of "virtual representation" can preclude a nonparty from maintaining a lawsuit based on a prior judgment against another party who sought the same relief.
The judgment is reversed.
Virtual representation is applied narrowly, since courts do not want to remove parties of their right to be heard in court based on cases in which they were not parties and could not assert their own interests.
- Court
- Supreme Court
- Decision Date
- April 16, 2008
- Jurisdiction
- federal
- Case Type
- landmark
- Majority Author
- Ginsburg
- Damages Awarded
- N/A
- Data Quality
- high
Will v. Hallock, 546 U.S. 345 (2006)
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Ballard v. Commissioner, 544 U.S. 40 (2005)
Consumer LostThe Supreme Court held that the Tax Court's practice of withholding special trial judges' reports from the public and excluding them from the record on appeal violates the principles of due process and transparency in judicial proceedings.
Marshall v. Marshall, 547 U.S. 293 (2006)
Consumer WonThe Supreme Court held that the Ninth Circuit's broad interpretation of the probate exception, which excluded federal jurisdiction over matters related to the validity of a decedent's estate planning instruments, was unwarranted and not supported by Congressional intent or prior Supreme Court decisions.
Sole v. Wyner, 551 U.S. 74 (2007)
Consumer LostA plaintiff who obtains a preliminary injunction but is ultimately denied a permanent injunction after a full adjudication on the merits does not qualify as a "prevailing party" under 42 U.S.C. §1988(b) for the purposes of recovering attorney's fees.