Monday, February 22, 2021

Pennsylvania Supreme Court Addresses Doctrines of Res Judicata As Well As Collateral Estoppel

In the case of In Re: Appeal of the Coatesville Area School District, No. 7 MAP 2020 (Pa. Jan. 20, 2021) (Op. by Saylor, C.J.), the court addressed the current status of the law in Pennsylvania regarding res judicata and the collateral estoppel doctrine in a case involving a tax appeal. 

Although this case involved a tax appeal, it is likely that the court’s pronouncement on the current status of the law regarding these doctrines would apply in all civil matters.

Under this decision, the court ruled that the Coatesville Areas School District should not have been barred from a merits resolution of its appeal of a tax assessment on the bases of res judicata (claim preclusion) and collateral estoppel (issue preclusion).  

In its decision, the court again confirmed that the doctrine of collateral estoppel focuses on issues rather than claims, whereas the res judicata doctrine more appropriately applies to the preclusion against relitigating entire claims a second time.   In the end, the Majority felt that the application of the doctrines was not warranted in this case.

Anyone wishing to review a copy of the Majority's decision may click this LINK. Justice Wecht's Dissenting Opinion can be viewed HERE. (The Dissenting Opinion also sets out the law nicely with respect to these doctrines).

Source: Article – “Pa Justices Define Contours of Res Judicata and Collateral Estoppel Doctrines, “ by P.J. D’Annunzio Pennsylvania Law Weekly (Jan. 22, 2021). 

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