Venue: |
SCOTUS
|
|
Facts: |
Officers of the company file materially false and misleading
proxy statement in connection with a merger. |
|
Posture: |
Stockholders' class action in federal district court: damages
recission of the merger, recovery of costs. Before trial,
the SEC files suit against some of the defendants (essentially
the same claims that the plaintiffs have here). There's a trial,
verdict for the SEC, affirmed by 2nd Cir. Now motion for
partial summary judgment here seeking to estop litigation on
issues determined in the SEC action. District court denies the
motion, 2nd Cir. reverses saying there has been a full and
fair opportunity to litiate. |
|
Issue: |
Can a litigant who was not a party to a prior judgment use preclusion
"offensively," to prevent relitigation of issues previously
resolved? |
|
Holding: |
Yes. |
|
Rule: |
If there has been a "full and fair" opportunity to litigate the
claim, estoppel applies. |
|
Reasoning: |
The law of estoppel has evolved, and it shapes the scope of the
jury's function. 7A right to a jury trial isn't absolute. |
|
Dicta: |
Rhenquist, dissenting: yeah, but this does violate 7A. |
|