Taylor v. Sturgell case brief summary
553 U.S. 880 (2008)
Petitioner, an individual who filed
suit under the Freedom of Information Act (FOIA), 5 U.S.C.S. §
552, sought review of a judgment from the United States Court of
Appeals for the District of Columbia Circuit affirming the district
court's dismissal of his action based on claim preclusion. The Court
granted certiorari to resolve the disagreement among the Circuits
over the permissibility and scope of preclusion based on "virtual
CASE FACTS The lower courts found that
petitioner's suit against respondent Federal Aviation Administration
was barred by the judgment in earlier litigation in which
petitioner's friend sought the same vintage airplane technical
documents that were sought by petitioner. Although petitioner was not
a party to his friend's suit, the lower courts found that the friend
was petitioner's "virtual representative."
disapproved the doctrine of preclusion by "virtual
representation" and held that the preclusive effects of a
judgment in a federal-question case decided by a federal court should
instead be determined according to the established six categories for
The court of appeals reached beyond those six
categories, and its definition of "adequate representation"
strayed from the meaning that the Court attributed to that term.
Court refused to adopt an amorphous balancing test that was at odds
with the Court's constrained approach to nonparty preclusion.
considering whether the result reached by the lower courts could be
justified based on one of the six established grounds, the Court
found that a remand was necessary to address the only applicable
The Court vacated the judgment. The Court remanded to give the
lower courts an opportunity to determine whether petitioner, in
pursuing the instant FOIA suit, was acting as his friend's agent.
Unanimous decision. Recommended Supplements for Civil Procedure
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