Mathews v. New York Racing Association, Inc.
193 F. Supp. 293 (S.D.N.Y. 1961)
-Mathews, the Plaintiff, attempted to bring a suit against the the Defendants, New York Racing Association, Inc. and Thoroughbred Racing Protective Association, Inc., its private detective agency. This suit was similar to a previous suit which had already been brought.
The Defendant invoked the defense of res judicata.
The Plaintiff alleged that on April 4, 1958 he was assaulted, kidnapped, falsely arrested and imprisoned by employees of Thoroughbred. The Plaintiff also alleged that the Defendants maliciously caused him to be prosecuted and imprisoned on April 10, 1958.
-The Plaintiff asked for money damages and an injunction restraining the Defendants from interfering with his presence at the racetrack, from publication of libelous statements and from acting as peace officers.
-The Defendants brought the defense of res judicata, asserting that a prior judgment which was dated June 30, 1960 dismissed his similar complaints.
-In that earlier case, the Plaintiff alleged on April 4, 1958 he was assaulted and libelous statements were made about him.
-In that earlier action, the Plaintiff also asked for monetary damages as well as an injunction from further interference with his attendance at the race track.
Is the claim alleged in this case the same as an earlier claim alleged by the Plaintiff and thus subject to the defense of res judicata?
Yes. The Plaintiff can not be allowed to split his claim into multiple suits and try them at his convenience.
Rules: The doctrine of res judicata operates as a bar to later suits which involve the same parties, or those in privity with them, based on a claim, that has once reached a judgment on the merits.
Res judicata is also known as claim preclusion. The term claim refers to a group of facts which are limited to a single occurrence or transaction without reference to the legal rights. It is the facts that surround the occurrence, not the legal theory, which make up the claim. The same facts were the basis of liability in each suit alleged. The Plaintiff already had his day in court. The previous judge had found that upon the facts and law the Plaintiff was not entitled to relief. Therefore, the Plaintiff was estopped from maintaining the current action.
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