State v. Werner (2005)

“The doctrine of collateral estoppel provides that ‘when an issue of ultimate fact has once been determined by a valid and final judgment, that issue cannot again be litigated between the same parties in any future lawsuit.’” State v. Gautier, 871 A.2d 347, 358 (R.I. 2005) (quoting State v. Werner, 865 A.2d 1049, 1055 (R.I. 2005)).

Because “an issue of ultimate fact”—that is, whether defendant was driving—was “determined by a valid and final judgment, that issue cannot again be litigated * * *.” State v. Gautier, 871 A.2d 347, 358 (R.I. 2005) (quoting State v. Werner, 865 A.2d 1049, 1055 (R.I. 2005)).

This Court has noted that “courts should adopt the reasoning of earlier judicial decisions if the same points arise again in litigation.” Woonsocket School Committee v. Chafee, 89 A.3d 778, 792 (R.I. 2014) (quoting State v. Werner, 865 A.2d 1049, 1056 (R.I. 2005)).

Applying Sundlun and CRMC to Plaintiffs’ Education Clause Claim It is appropriate at this juncture to note that, “[u]nder the doctrine of stare decisis, ‘courts should adopt the reasoning of earlier judicial decisions if the same points arise again in litigation.’ ” State v. Werner, 865 A.2d 1049, 1056 (R.I. 2005) (quoting Johnston Ambulatory Surgical Associates, Ltd. v. Nolan, 755 A.2d 799, 807 (R.I.2000)).

We rejected that request, noting that “this Court will consider overturning precedent only ‘if the motivating purpose is to eliminate inconsistency and anomalous results’ ” and that “[t]he defendant proffer[ed] no evidence to suggest that the present case undermine[d] our existing law.” Id. at 406 (quoting State v. Werner, 865 A.2d 1049, 1056 (R.I.2005)).

State v. Gautier, 871 A.2d 347, 358 (R.I.2005); State v. Werner, 865 A.2d 1049, 1055 (R.I.2005); Foster-Glocester Regional School Committee, 854 A.2d at 1014 .

We note that this Court will consider overturning precedent only “ ‘if the motivating purpose is to eliminate inconsistency and anomalous results.’ ” State v. Werner, 865 A.2d 1049, 1056 (R.I.2005).

The doctrine of collateral estoppel provides that “ ‘when an issue of ultimate fact has once been determined by a valid and final judgment, that issue cannot again be litigated between the same parties in any future lawsuit.’ ” State v. Werner, 865 A.2d 1049, 1055 (R.I.2005) (quoting Santiago II, 847 A.2d at 254 ).

See State v. Werner , 865 A.2d 1049 , 1055 (R.I. 2005) (explaining that for collateral estoppel to apply, there must be "`(1) an identity of issues, (2) the previous proceeding must have resulted in a final judgment on the merits , and (3) the party against whom collateral estoppel is asserted must be the same or in privity with a party in the previous proceeding[]'") (quoting State v. Santiago , 847 A.2d 252 , 254 (R.I. 2004)).