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Law School Case Briefs
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Taylor v. Sturgell
Supreme Court of the United States (2008) | 171 L. Ed. 2d 155; 128 S. Ct. 2161; 553 U.S. 880; 2008 U.S. LEXIS 4885; 36 Media L. Rep. (BNA) 1801; 76 U.S.L.W. 4453; 21 Fla. L. Weekly Fed. S 323
TL;DR: The Supreme Court rejected the “virtual representation” doctrine, holding that a nonparty is not bound by a prior judgment simply because of a close relationship and identical interests with a litigant. Nonparty preclusion is permissible only under six narrow, traditional exceptions.
Legal Significance: This case definitively rejects amorphous, multi-factor tests for nonparty preclusion, solidifying a clear, rule-based framework. It enumerates the six exclusive exceptions to the general rule that a person is not bound by a judgment in a case to which they were not a party.
