collateral estoppel doctrine in Minnesota

1993See Hauser v. Mealey, 263 N.W.2d 803, 808 (Minn.1978) (where a judgment may be based on one or more grounds, but did not expressly rely on any one of them, none of the grounds are conclusively established under the doctrine of collateral estoppel).

1989Hauser v. Mealey, 263 N.W.2d 803, 806 (Minn.1978); McBroom v. AlChroma, Inc., 386 N.W.2d 369, 372 (Minn.Ct.App.1986).

2016Collateral estoppel "precludes parties from relitigating issues which are identical to issues previously litigated and which were necessary and essential to the former resulting judgment.” Aufderhar v. Data Dispatch, Inc., 452 N.W.2d 648, 650 (Minn.1990).

1995Nonetheless, citing the Minnesota Supreme Court's decision in Aufderhar v. Data Dispatch, Inc., 452 N.W.2d 648, 653-54 (Minn.1990), the ALJ applied the doctrine of collateral estoppel because Falgren's "choice of arbitration constitutes a voluntary limiting of the review available." We disagree with the ALJ for three reasons.

1996Ellis v. Minneapolis Comm’n on Civil Rights, 319 N.W.2d 702, 704 (Minn.1982) (quoting Victory Highway Village, Inc. v. Weaver, 480 F.Supp. 71, 74 (D.Minn.1979)).

1984We agree that this purportedly independent action is barred by the doctrine of collateral estoppel. *186 The essential nature of this aspect of res judicata was recently stated with clarity in Ellis v. Minneapolis Comm'n on Civil Rights, 319 N.W.2d 702 (Minn.1982).

1985The statute codifies the common law doctrine of collateral estoppel, a form of res judicata “whereby a former judgment is conclusive in a later suit between the same parties or their privies as to determinative issues finally decided in the former suit.” Travelers Insurance Co. v. Thompson, 281 Minn. 547, 551 , 163 N.W.2d 289, 292 (1968), appeal dismissed, 395 U.S. 161 , 89 S.Ct. 1647 , 23 L.Ed.2d 175 (1969).

1985The statute codifies the common law doctrine of collateral estoppel, a form of res judicata “whereby a former judgment is conclusive in a later suit between the same parties or their privies as to determinative issues finally decided in the former suit.” Travelers Insurance Co. v. Thompson, 281 Minn. 547, 551 , 163 N.W.2d 289, 292 (1968), appeal dismissed, 395 U.S. 161 , 89 S.Ct. 1647 , 23 L.Ed.2d 175 (1969).

1989The doctrine of collateral estoppel operates to “preclude relitigation of the same issues which were actually litigated and necessary to the determination of a previous judgment.” McBroom v. Al-Chroma, Inc., 386 N.W.2d 369, 373 (Minn.Ct.App.1986). [Collateral estoppel] applies where (1) the issue was identical to one in a prior adjudication; (2) there was a final judgment on the merits; (3) the estopped party was a party or in privity with a party to the prior adjudication; and (4) the estopped party was given a full and fair opportunity to be heard on an adjudicated issue.

1989Hauser v. Mealey, 263 N.W.2d 803, 806 (Minn.1978); McBroom v. AlChroma, Inc., 386 N.W.2d 369, 372 (Minn.Ct.App.1986).

2023The doctrine of collateral estoppel applies if: (1) the issue is “identical to the one in a prior adjudication,” (2) “there was a final judgment on the merits,” (3) “the estopped party was a party or in privity with a party to the prior adjudication,” and (4) “the estopped party was given a full and fair opportunity to be heard on the issue.” Id. (quotation omitted).

2023The doctrine of collateral estoppel applies if: (1) the issue is “identical to the one in a prior adjudication,” (2) “there was a final judgment on the merits,” (3) “the estopped party was a party or in privity with a party to the prior adjudication,” and (4) “the estopped party was given a full and fair opportunity to be heard on the issue.” Id. (quotation omitted).

2017Barth v. Stenwick, 761 N.W.2d 502, 508 (Minn. App. 2009).

2015See Heine, 702 N.W.2d at 761 ; see also Bechtold v. City of Rosemount, 104 F.3d 1062, 1066-67 (8th Cir. 1997) (holding that issue of pretext in plaintiff’s Title VII claim is same as issue of wrongful termination in plaintiff’s prior certiorari review by this court). 8 B.

2015See Heine, 702 N.W.2d at 761 ; see also Bechtold v. City of Rosemount, 104 F.3d 1062, 1066-67 (8th Cir. 1997) (holding that issue of pretext in plaintiff’s Title VII claim is same as issue of wrongful termination in plaintiff’s prior certiorari review by this court). 8 B.

2015Second Requirement: Final Adjudication on the Merits The second requirement of the doctrine of collateral estoppel is that “there must have been a final adjudication on the merits.” Heine, 702 N.W.2d at 761 (quotation omitted).

2015Hauschildt v. Beckingham, 686 N.W.2d 829, 837 (Minn. 2004). 4 Rucker v. Schmidt, 794 N.W.2d 114, 117 (Minn. 2011) (footnote omitted).

2015See, e.g., Burns v. Commissioner of Revenue, 787 N.W.2d 164, 166-67 (Minn. 2010).

2015Thus, for purposes of resolving this appeal, we assume that the doctrine applies. 5 A. First Requirement: Identical Issues To reiterate, the first requirement of the doctrine of collateral estoppel is that “the issues in the prior and present adjudication [are] identical.” Id. (quotation omitted).

2015See Haavisto, 520 N.W.2d at 731 .

2013See In re Estate of Congdon, 309 N.W.2d 261, 270 (Minn.1981) (explaining that “the different degree of the burden of proof between criminal and civil cases also precludes application of the doctrine of ‘res judicata’ ”); United States v. One Assortment of 89 Firearms, 465 U.S. 354, 362 , 104 S.Ct. 1099 , 79 L.Ed.2d 361 (1984) (stating that “the difference in the relative burdens of proof in the criminal and civil actions precludes the application of the doctrine of collateral estoppel”).

2005But we have noted that "[a] right to a jury trial ordinarily may not be abridged by the doctrine of collateral estoppel." Id. at 355 (holding that an employee was not estopped from pursuing issues previously litigated when he had been improperly denied a jury trial in his previous action).

2005But we have noted that “[a] right to a jury trial ordinarily may not be abridged by the doctrine of collateral estoppel.” Id. at 355 (holding that an employee was not es-topped from pursuing issues previously litigated when he had been improperly denied a jury trial in his previous action).

2002A. Collateral Estoppel The doctrine of collateral estop-pel is employed to prevent “parties to an action from relitigating in subsequent actions issues that were determined in the prior action.” In Re Special Assessment for Water Main Extension in the Vill. of Byron, 255 N.W.2d 226, 228 (Minn.1977).

2000See Maplewood, 576 N.W.2d at 737 .

2000See Reil v. Benjamin, 584 N.W.2d 442, 445 (Minn.App.1998) (person in privity with a party to a prior action collaterally estopped), review denied (Minn. Nov. 17, 1998).

1999See Johnson v. Consolidated Freightways, Inc., 420 N.W.2d 608, 613-614 (Minn.1988) (no “full and fair opportunity” to litigate issue of comparative fault, where only part of the pertinent facts and witnesses were available at prior proceeding).

1996Ellis v. Minneapolis Comm’n on Civil Rights, 319 N.W.2d 702, 704 (Minn.1982) (quoting Victory Highway Village, Inc. v. Weaver, 480 F.Supp. 71, 74 (D.Minn.1979)).

1995See In re Trusts Created by Hormel, 504 N.W.2d 505, 509 (Minn. App.1993) ("Whether collateral estoppel is available is a mixed question of law and fact subject to de novo review"), pet. for rev. denied (Minn. Oct. 19, 1993).