Collateral Estoppel

Under the doctrine of collateral estoppel, a party to a legal action is prevented from relitigating an issue of fact or law when that same issue was resolved against that party in a prior case in which the party had a full and fair opportunity to litigate the issue.

“The doctrine of collateral estoppel, or issue preclusion, bars a party from relitigating in a second proceeding an issue of fact or law that was litigated and actually decided in a prior proceeding, if that party had a full and fair opportunity to litigate the issue in the prior proceeding and the decision of the issue was necessary to support a valid and final judgment on the merits.”  Metromedia Co. v. Fugazy, 983 F.2d 350 (2d Cir. 1992).

“Collateral estoppel, or issue preclusion, prevents the relitigation of an issue that was raised, litigated, and actually decided by a judgment in a prior proceeding.  Issues that may bear the same label are nonetheless not identical if the standards governing them are significantly different . If an issue was not actually decided in a prior proceeding, or if its decision was not necessary to the judgment, its litigation in a subsequent proceeding is not barred by collateral estoppel.”  Jim Beam Brands Co. v. Beamish Crawford Ltd., 937 F.2d 729 (2d Cir. 1991).

A decision by an administrative agency cannot be the basis for collateral estoppel unless the agency’s decision was an adjudicative decision.  An agency action granting or denying a privilege is not an adjudicative decision unless the agency has made its decision using procedures substantially similar to those employed by the courts.

The finality required for the collateral estoppel doctrine is not the same as the finality required for appeal.  For purposes of equitable estoppel, the ruling on the relevant issue in the prior case need not end the litigation leaving nothing for court but execution of judgment but can include dispositions which, though not final in that sense, have nonetheless been fully litigated.  Thus, “finality” for purposes of collateral estoppel may mean little more than that the litigation of a particular issue has reached such a stage that a court sees no good reason for permitting it to be litigated again.

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