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). 

Detailed Opinion out of Lackawanna County on Defamation, Fraud, Res Judicata, and Collateral Estoppel Issues

For those of you who deal with the torts of defamation and fraud, and for those of you who are facing a res judicata or collateral estoppel issue, I have come across a recent Opinion by Judge Terrence R. Nealon of the Lackawanna County Court of Common Pleas outlining the current status of the law on these causes of action in the case of Davis v. PPL Sustainable Energy Fund, 10 - CV - 706 (C.P. Lacka. Co. Oct. 13, 2011 Nealon, J.)

This case involved a former board member of a non-profit energy conservation fund who sued the fund's directors and agents alleging fraud and defamation in orchestrating his removal from the board.  Judge Nealon denied the Defendant's motion for judgment on the pleadings and found that the Plaintiff had indeed stated valid causes of action for defamation and fraud.

The Opinion also analyzes in detail the difference between the doctrines of res judicata and collateral estoppel in terms of the defense argument that the Plaintiff's claims were previously adjudicated before an administrative agency.  The trial court found that the Plaintiff was not precluded from pursuing the claims presented since the tort claims were not at issue in the prior administrative proceedings.

Anyone desiring a copy of Judge Nealon's 28 page Opinion in the case of Davis v. PPL Sustainable Energy Fund may contact me at dancummins@comcast.net.