Sunday, November 24, 2013

Taylor v. Sturgell case brief

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 representation."

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."


  • The Court 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 nonparty preclusion. 
  • 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. 
  • The Court refused to adopt an amorphous balancing test that was at odds with the Court's constrained approach to nonparty preclusion. 
  • In 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 ground.
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.

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