estoppel by judgment doctrine (Florida) · Go Syfert
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estoppel by judgment doctrine in Florida

31 Florida opinions name it 2 courts 1955–2014 0 in the last five years

The cases below were cited by Florida courts in a sentence that names this issue. Sides come from how each citing opinion treated the case (Syfertize flag on that citation), so a case can appear on both: that is where the law is contested. A red or yellow chip is the case's own overall treatment.

Followed or applied (16)

CaseFollowedCited
Gordon v. Gordongreen
fla · 1952 · cited in 6 Florida opinions naming this issue, 1955–1996
2 sentences

1996As the supreme court bluntly noted in Gordon v. Gordon, 59 So.2d 40, 44 (Fla.1952), cert. denied, 344 U.S. 878 , 73 S.Ct. 165 , 97 L.Ed. 680 (1952), the doctrine of estoppel by judgment, or collateral estoppel, “rests upon equitable principles.” We note, however, that Judge Carney found little equity — much less an estoppel — in defendant’s contention.

1956In Gordon v. Gordon, Fla., 59 So.2d 40, 44 , we undertook to distinguish between the two doctrines and said that under res judicata a final judgment or decree not only bars a later suit "between the same parties based upon the same cause of action" but also upon matters that "could have been raised" while under the doctrine of estoppel by judgment, the two causes of action might be different and the judgment or decree in the first would only estop the "parties from litigating in the second suit issues — that is to say points and questions — common to both causes of action and which were actual

36
Seaboard Coast Line R. Co. v. Coxgreen
fla · 1976 · cited in 3 Florida opinions naming this issue, 1977–1992
2 sentences

1992Krug v. Meros, 468 So.2d 299 (Fla. 2d DCA), rev. denied, 480 So.2d 1295 (Fla.1985); Seaboard Coast Line R.R. v. Cox, 338 So.2d 190 (Fla.1976).

1985See generally, Seaboard Coastline Railroad Co. v. Cox, 338 So.2d 190 (Fla.1976); City of Hialeah Gardens v. Prieto, 353 So.2d 200 (Fla. 3d DCA 1977); Zurich Insurance Co. v. Bartlett, 352 So.2d 921 (Fla. 2d DCA 1977).

23
Krug v. Merosgreen
fladistctapp · 1985 · cited in 2 Florida opinions naming this issue, 1992–2014
2 sentences

2014See Haskin v. Haskin, 781 So.2d 431, 482 (Fla. 4th DCA 2001); Krug v. Meros, 468 So.2d 299, 303 (Fla. 2d DCA 1985) (“[W]e note that the doctrine of estoppel by judgment does not apply where unanticipated subsequent events create a new legal situation.”). “[T]he determination of whether a significant change in circumstances has occurred lies primarily within the discretion of the administrative agency.” Delray Med.

1992Krug v. Meros, 468 So.2d 299 (Fla. 2d DCA), rev. denied, 480 So.2d 1295 (Fla.1985); Seaboard Coast Line R.R. v. Cox, 338 So.2d 190 (Fla.1976).

12
Miller v. E. I. duPont de Nemours & Co.green
scotus · 1952 · cited in 2 Florida opinions naming this issue, 1991–1996
2 sentences

1996As the supreme court bluntly noted in Gordon v. Gordon, 59 So.2d 40, 44 (Fla.1952), cert. denied, 344 U.S. 878 , 73 S.Ct. 165 , 97 L.Ed. 680 (1952), the doctrine of estoppel by judgment, or collateral estoppel, “rests upon equitable principles.” We note, however, that Judge Carney found little equity — much less an estoppel — in defendant’s contention.

1991See Gordon v. Gordon, 59 So.2d 40, 43-44 (Fla. 1952), cert. denied, 344 U.S. 878 , 73 S.Ct. 165 , 97 L.Ed. 680 (1952).

12
Gordon v. Gordongreen
scotus · 1952 · cited in 2 Florida opinions naming this issue, 1991–1996
2 sentences

1996As the supreme court bluntly noted in Gordon v. Gordon, 59 So.2d 40, 44 (Fla.1952), cert. denied, 344 U.S. 878 , 73 S.Ct. 165 , 97 L.Ed. 680 (1952), the doctrine of estoppel by judgment, or collateral estoppel, “rests upon equitable principles.” We note, however, that Judge Carney found little equity — much less an estoppel — in defendant’s contention.

1991See Gordon v. Gordon, 59 So.2d 40, 43-44 (Fla. 1952), cert. denied, 344 U.S. 878 , 73 S.Ct. 165 , 97 L.Ed. 680 (1952).

12
State Ex Rel. Hay v. Farnumgreen
sc · 1905 · cited in 2 Florida opinions naming this issue, 1991–1996
2 sentences

1996As the supreme court bluntly noted in Gordon v. Gordon, 59 So.2d 40, 44 (Fla.1952), cert. denied, 344 U.S. 878 , 73 S.Ct. 165 , 97 L.Ed. 680 (1952), the doctrine of estoppel by judgment, or collateral estoppel, “rests upon equitable principles.” We note, however, that Judge Carney found little equity — much less an estoppel — in defendant’s contention.

1991See Gordon v. Gordon, 59 So.2d 40, 43-44 (Fla. 1952), cert. denied, 344 U.S. 878 , 73 S.Ct. 165 , 97 L.Ed. 680 (1952).

12
Delray Medical Center, Inc. v. State Agency for Health Care Administrationgreen
fladistctapp · 2009 · cited in 1 Florida opinions naming this issue, 2014–2014
1 sentence

2014Ctr., Inc. v. State Agency for Health Care Admin., 5 So.3d 26, 29 (Fla. 4th DCA 2009).

11
Haskin v. Haskingreen
fladistctapp · 2001 · cited in 1 Florida opinions naming this issue, 2014–2014
1 sentence

2014See Haskin v. Haskin, 781 So.2d 431, 482 (Fla. 4th DCA 2001); Krug v. Meros, 468 So.2d 299, 303 (Fla. 2d DCA 1985) (“[W]e note that the doctrine of estoppel by judgment does not apply where unanticipated subsequent events create a new legal situation.”). “[T]he determination of whether a significant change in circumstances has occurred lies primarily within the discretion of the administrative agency.” Delray Med.

11
Cromwell v. County of Sacgreen
scotus · 1877 · cited in 1 Florida opinions naming this issue, 1992–1992
1 sentence

1992See Birge v. Simpson, 280 So.2d 482 (Fla. 1st DCA 1973) (duty of support owed by noncustodial mother is "equal"); Condon v. Condon, 295 So.2d 681, 683 (Fla. 1st DCA 1974) ("It is inescapable that the duty of support is owed by both natural parents"); Cronebaugh v. Van Dyke, 415 So.2d 738, 741 (Fla. 5th DCA 1982), rev. denied 426 So.2d 25 (Fla. 1983) (parental support duty "is independent of any settlement agreement made attendant upon dissolution"). [1] If the claims are not identical, then the doctrine of estoppel by judgment would apply, and the prior order would operate "as an estoppel only

11
Cronebaugh v. Van Dykegreen
fladistctapp · 1982 · cited in 1 Florida opinions naming this issue, 1992–1992
1 sentence

1992See Birge v. Simpson, 280 So.2d 482 (Fla. 1st DCA 1973) (duty of support owed by noncustodial mother is "equal"); Condon v. Condon, 295 So.2d 681, 683 (Fla. 1st DCA 1974) ("It is inescapable that the duty of support is owed by both natural parents"); Cronebaugh v. Van Dyke, 415 So.2d 738, 741 (Fla. 5th DCA 1982), rev. denied 426 So.2d 25 (Fla. 1983) (parental support duty "is independent of any settlement agreement made attendant upon dissolution"). [1] If the claims are not identical, then the doctrine of estoppel by judgment would apply, and the prior order would operate "as an estoppel only

11
Condon v. Condongreen
fladistctapp · 1974 · cited in 1 Florida opinions naming this issue, 1992–1992
1 sentence

1992See Birge v. Simpson, 280 So.2d 482 (Fla. 1st DCA 1973) (duty of support owed by noncustodial mother is "equal"); Condon v. Condon, 295 So.2d 681, 683 (Fla. 1st DCA 1974) ("It is inescapable that the duty of support is owed by both natural parents"); Cronebaugh v. Van Dyke, 415 So.2d 738, 741 (Fla. 5th DCA 1982), rev. denied 426 So.2d 25 (Fla. 1983) (parental support duty "is independent of any settlement agreement made attendant upon dissolution"). [1] If the claims are not identical, then the doctrine of estoppel by judgment would apply, and the prior order would operate "as an estoppel only

11
Birge v. Simpsongreen
fladistctapp · 1973 · cited in 1 Florida opinions naming this issue, 1992–1992
1 sentence

1992See Birge v. Simpson, 280 So.2d 482 (Fla. 1st DCA 1973) (duty of support owed by noncustodial mother is "equal"); Condon v. Condon, 295 So.2d 681, 683 (Fla. 1st DCA 1974) ("It is inescapable that the duty of support is owed by both natural parents"); Cronebaugh v. Van Dyke, 415 So.2d 738, 741 (Fla. 5th DCA 1982), rev. denied 426 So.2d 25 (Fla. 1983) (parental support duty "is independent of any settlement agreement made attendant upon dissolution"). [1] If the claims are not identical, then the doctrine of estoppel by judgment would apply, and the prior order would operate "as an estoppel only

11
TRUCKING EMP. OF N. JERSEY WELFARE FUND, INC. v. Romanogreen
fla · 1984 · cited in 1 Florida opinions naming this issue, 1990–1990
1 sentence

1990See, Trucking Employees of North Jersey Welfare Fund, Inc. v. Romano, 450 So.2d 843 (Fla.1984).

11
Ashe v. Swensongreen
scotus · 1970 · cited in 1 Florida opinions naming this issue, 1987–1987
2 sentences

1987See Ashe v. Swenson, 397 U.S. 436 , 90 S.Ct. 1189 , 25 L.Ed.2d 469 (1970).

1987See Ashe v. Swenson, 397 U.S. 436 , 90 S.Ct. 1189 , 25 L.Ed.2d 469 (1970).

11
Remington Construction Co. v. Hamilton Electric, Inc.green
fladistctapp · 1965 · cited in 1 Florida opinions naming this issue, 1978–1978
11
Gray v. Graygreen
fla · 1926 · cited in 1 Florida opinions naming this issue, 1965–1965
11

Distinguished, questioned or overruled (0)

CaseNegativeCited
No negative-treatment citations attached to this issue in Florida. Read the followed side critically anyway.

Also cited on this issue (34)

CaseCitedYears
Seaboard Coast LR Co. v. Industrial Contracting Company green
fladistctapp · 1972
2 sentences

1986Seaboard Coast Line Railroad v. Industrial Contracting Company, 260 So.2d 860 (Fla. 4th DCA 1972).

1985Gordon ; Prall v. Prall, 50 So. 867 (Fla. 1909); Sun State Roofing Co.; Seaboard Coast Line R.R. v. Industrial Contracting Co., 260 So.2d 860 (Fla. 4th DCA 1972); Stone v. Stone, 111 So.2d 486 (Fla. 3d DCA 1959).

31977–1986
Zurich Ins. Co. v. Bartlett green
fladistctapp · 1977
2 sentences

1986Zurich Insurance Company v. Bartlett, 352 So.2d 921 (Fla. 2d DCA 1977).

1985See generally, Seaboard Coastline Railroad Co. v. Cox, 338 So.2d 190 (Fla.1976); City of Hialeah Gardens v. Prieto, 353 So.2d 200 (Fla. 3d DCA 1977); Zurich Insurance Co. v. Bartlett, 352 So.2d 921 (Fla. 2d DCA 1977).

21985–1986
Universal Const. Co. v. City of Fort Lauderdale green
fla · 1953
2 sentences

1972The distinction between the two has recently received the attention of the Court, in Gordon v. Gordon, Fla., 59 So.2d 40 ; Donahue v. Davis, Fla., 68 So.2d 163 , and Universal Const. Co. v. City of Fort Lauderdale, Fla., 68 So.2d 366 .

1955The distinction between the two has recently received the attention of the Court, in Gordon v. Gordon, Fla., 59 So.2d 40 ; Donahue v. Davis, Fla., 68 So.2d 163 , and Universal Const. Co. v. City of Fort Lauderdale, Fla., 68 So.2d 366 .

21955–1972
Donahue v. Davis green
fla · 1953
2 sentences

1972The distinction between the two has recently received the attention of the Court, in Gordon v. Gordon, Fla., 59 So.2d 40 ; Donahue v. Davis, Fla., 68 So.2d 163 , and Universal Const. Co. v. City of Fort Lauderdale, Fla., 68 So.2d 366 .

1955The distinction between the two has recently received the attention of the Court, in Gordon v. Gordon, Fla., 59 So.2d 40 ; Donahue v. Davis, Fla., 68 So.2d 163 , and Universal Const. Co. v. City of Fort Lauderdale, Fla., 68 So.2d 366 .

21955–1972
Mobil Oil Corp. v. Shevin green
fla · 1977
1 sentence

1992Mobil Oil Corp. v. Shevin, 354 So.2d 372 (Fla. 1977).

11992–1992
City of Hialeah Gardens v. Prieto green
fladistctapp · 1977
1 sentence

1985See generally, Seaboard Coastline Railroad Co. v. Cox, 338 So.2d 190 (Fla.1976); City of Hialeah Gardens v. Prieto, 353 So.2d 200 (Fla. 3d DCA 1977); Zurich Insurance Co. v. Bartlett, 352 So.2d 921 (Fla. 2d DCA 1977).

11985–1985
Hialeah Race Course, Inc. v. GULFSTREAM PK. R. ASS'N green
fla · 1971
1 sentence

1985Hialeah Race Course, Inc. v. Gulfstream Park Racing Association, 245 So.2d 625 (Fla. 1971); Wagner v. Baron, 64 So.2d 267 (Fla. 1953).

11985–1985
Allstate Ins. Co. v. ADH, INC. green
fladistctapp · 1981
1 sentence

1985Prall ; Architectural Research, Inc. v. Stetson, 444 So.2d 973 (Fla. 4th DCA 1983), petition for review denied, 453 So.2d 45 (Fla. 1984); Freehling v. MGIC Financial Corp., 437 So.2d 191 (Fla. 4th DCA 1983); Sun State Roofing Co.; Allstate Insurance Co. v. A.D.H., Inc., 397 So.2d 928 (Fla. 3d DCA 1981); Seaboard Coast Line R.R. v. Industrial Contracting Co .; Stone.

11985–1985
Wagner v. Baron green
fla · 1953
1 sentence

1985Hialeah Race Course, Inc. v. Gulfstream Park Racing Association, 245 So.2d 625 (Fla. 1971); Wagner v. Baron, 64 So.2d 267 (Fla. 1953).

11985–1985
Freehling v. MGIC Financial Corp. green
fladistctapp · 1983
1 sentence

1985Prall ; Architectural Research, Inc. v. Stetson, 444 So.2d 973 (Fla. 4th DCA 1983), petition for review denied, 453 So.2d 45 (Fla. 1984); Freehling v. MGIC Financial Corp., 437 So.2d 191 (Fla. 4th DCA 1983); Sun State Roofing Co.; Allstate Insurance Co. v. A.D.H., Inc., 397 So.2d 928 (Fla. 3d DCA 1981); Seaboard Coast Line R.R. v. Industrial Contracting Co .; Stone.

11985–1985
Stone v. Stone green
fladistctapp · 1959
1 sentence

1985Gordon ; Prall v. Prall, 50 So. 867 (Fla. 1909); Sun State Roofing Co.; Seaboard Coast Line R.R. v. Industrial Contracting Co., 260 So.2d 860 (Fla. 4th DCA 1972); Stone v. Stone, 111 So.2d 486 (Fla. 3d DCA 1959).

11985–1985
Architectural Research, Inc. v. Stetson neutral
fladistctapp · 1983
1 sentence

1985Prall ; Architectural Research, Inc. v. Stetson, 444 So.2d 973 (Fla. 4th DCA 1983), petition for review denied, 453 So.2d 45 (Fla. 1984); Freehling v. MGIC Financial Corp., 437 So.2d 191 (Fla. 4th DCA 1983); Sun State Roofing Co.; Allstate Insurance Co. v. A.D.H., Inc., 397 So.2d 928 (Fla. 3d DCA 1981); Seaboard Coast Line R.R. v. Industrial Contracting Co .; Stone.

11985–1985
Thompson v. DEPT. OF HEALTH & REHAB. SERV. green
fladistctapp · 1977
1 sentence

1982Thus, before a litigant is barred under the doctrine of estoppel by judgment, it must appear that the points or questions involved in the subsequent action were determined in the prior action. *415 It is established law that the termination of the natural parents' rights by commitment proceedings does not foreclose their right to seek adoption pursuant to Chapter 63, supra. In the Interest of C.M.M., supra ; Thompson v. Department of Health and Rehabilitative Services, supra .

11982–1982
Youngblood v. Taylor green
fla · 1956
1 sentence

1982Youngblood v. Taylor, 89 So.2d 503 (Fla. 1956).

11982–1982
Harmon v. Department of Health & Rehabilitative Services neutral
fladistctapp · 1978
1 sentence

1982Thus, before a litigant is barred under the doctrine of estoppel by judgment, it must appear that the points or questions involved in the subsequent action were determined in the prior action. *415 It is established law that the termination of the natural parents' rights by commitment proceedings does not foreclose their right to seek adoption pursuant to Chapter 63, supra. In the Interest of C.M.M., supra ; Thompson v. Department of Health and Rehabilitative Services, supra .

11982–1982
Buckley Towers Condominium, Inc. v. Buchwald neutral
fladistctapp · 1979
1 sentence

1982Cf. Buckley Towers Condominium, Inc. v. Buchwald, 374 So.2d 550 (Fla. 3d DCA 1979), dismissed, 386 So.2d 634 (Fla. 1980) (appellate court's express refusal in earlier appeal to consider issue of legality of recreation lease does not bar, under doctrine of estoppel by judgment, subsequent action raising that issue).

11982–1982
St. Louis Baptist Temple, Inc. v. Federal Deposit Insurance Corporation green
ca10 · 1979
11981–1981
American National Bank & Trust Co. of Ft. Lauderdale v. Egidi green
fladistctapp · 1980
11981–1981
Burke v. Dade County neutral
fladistctapp · 1980
11981–1981
Montford v. Wainwright green
fla · 1964
11980–1980
Simco Operating Corp. v. CITY NAT. BANK, ETC. green
fladistctapp · 1976
11980–1980
Smith v. Florida East Coast Railway Company green
fladistctapp · 1963
11980–1980
Buckley Towers Condominium, Inc. v. Buchwald green
fladistctapp · 1976
11979–1979
Buckley Towers Condominium, Inc. v. Buchwald green
fladistctapp · 1975
11979–1979
Diplomat Electric, Inc. v. Westinghouse Electric Supply Company green
ca5 · 1970
11977–1977
Hoffman v. Jones green
fla · 1973
11975–1975
McGregor v. Provident Trust Co. green
fla · 1935
11974–1974
Martin v. Arrow Cabs green
fladistctapp · 1958
11972–1972
Shell Oil Company v. Texas Gas Transmission Corp. green
lactapp · 1965
11971–1971
Hill v. Colonial Enterprises, Inc. green
fladistctapp · 1969
11971–1971
Ake v. Birnbaum green
fla · 1945
11969–1969
Prall v. Prall green
fla · 1909
11959–1959
Gordon v. Gordon green
fla · 1948
11956–1956
Bagwell v. Bagwell green
fla · 1943
11956–1956

Where else courts name it

FL 31 (1955–2014) GA 26 (1906–2017) OK 13 (1942–1999) IL 12 (1944–1992) OH 4 (1962–1989) TX 4 (1961–2017) MO 3 (1933–2008) LA 3 (1973–1977) MI 2 (1942–1958) ME 2 (1887–1970) AZ 2 (1918–1930) SC 2 (1959–1976) MN 2 (1926–1929) MS 2 (1951–2024) VA 2 (1965–1976)

Opinions by the citing court's state. A doctrine retained in one state and abandoned in another shows up here as a year span that stalls.

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