res judicata doctrine in Maryland

2021See Colandrea v. Wilde Lake Cmty. Ass’n, 361 Md. 371, 392 , 761 A.2d 899, 910 (2000) (noting one of the requirements of the doctrine of res judicata is whether “the claim presented in the current action is identical to the one determined in the prior adjudication[]”) (emphasis added).

2021See Colandrea v. Wilde Lake Cmty. Ass’n, 361 Md. 371, 392 , 761 A.2d 899, 910 (2000) (noting one of the requirements of the doctrine of res judicata is whether “the claim presented in the current action is identical to the one determined in the prior adjudication[]”) (emphasis added).

1998The doctrine of res judicata provides that “a judgment between the same parties and their privies is a final bar to any other suit upon the same cause of action, and is conclusive, not only as to all matters that have been decided in the original suit, but as to all matters which with propriety could have been litigated in the first suit....” deLeon v. Slear, 328 Md. 569, 580 , 616 A.2d 380 (1992) (quoting Alvey v. Alvey, 225 Md. 386, 390 , 171 A.2d 92 (1961)); see Rowland v. Harrison, 320 Md. 223, 229 , 577 A.2d 51 (1990); Warner v. German, 100 Md.App. 512, 518 , 642 A.2d 239 (1994).

1998The doctrine of res judicata provides that “a judgment between the same parties and their privies is a final bar to any other suit upon the same cause of action, and is conclusive, not only as to all matters that have been decided in the original suit, but as to all matters which with propriety could have been litigated in the first suit....” deLeon v. Slear, 328 Md. 569, 580 , 616 A.2d 380 (1992) (quoting Alvey v. Alvey, 225 Md. 386, 390 , 171 A.2d 92 (1961)); see Rowland v. Harrison, 320 Md. 223, 229 , 577 A.2d 51 (1990); Warner v. German, 100 Md.App. 512, 518 , 642 A.2d 239 (1994).

2018Collateral estoppel provides that, "[w]hen an issue of fact or law is actually litigated and determined by a valid and final judgment, and the determination is essential to the judgment, the determination is conclusive in a subsequent action between the parties, whether on the same or a different claim." Cosby v. Dep't of Human Res. , 425 Md. 629 , 639, 42 A.3d 596 (2012) ; see also Rourke v. Amchem Products, Inc. , 384 Md. 329 , 359, 863 A.2d 926 , 944 (2004) (quoting re Murray Int'l Freight Corp. v. Graham , 315 Md. 543 , 547, 555 A.2d 502 , 503 (1989) ("The functions of this doctrine, and t

2018Collateral estoppel provides that, "[w]hen an issue of fact or law is actually litigated and determined by a valid and final judgment, and the determination is essential to the judgment, the determination is conclusive in a subsequent action between the parties, whether on the same or a different claim." Cosby v. Dep't of Human Res. , 425 Md. 629 , 639, 42 A.3d 596 (2012) ; see also Rourke v. Amchem Products, Inc. , 384 Md. 329 , 359, 863 A.2d 926 , 944 (2004) (quoting re Murray Int'l Freight Corp. v. Graham , 315 Md. 543 , 547, 555 A.2d 502 , 503 (1989) ("The functions of this doctrine, and t

2010The oft quoted definition of res judicata by this Court is that found in MPC, Inc. v. Kenny, 279 Md. 29, 32 , 367 A.2d 486, 488-89 (1977): “the doctrine of res judicata is that a judgment between the same parties and their privies is a final bar to any other suit upon the same cause of action, and is conclusive, not only as to all matters that have been decided in the original suit, but as to all matters which with propriety could have been litigated in the first suit[J” See also Restatement § 17. 10 The parties in Brent I and II are different so that the question arises whether master and ser

2010The oft quoted definition of res judicata by this Court is that found in MPC, Inc. v. Kenny, 279 Md. 29, 32 , 367 A.2d 486, 488-89 (1977): “the doctrine of res judicata is that a judgment between the same parties and their privies is a final bar to any other suit upon the same cause of action, and is conclusive, not only as to all matters that have been decided in the original suit, but as to all matters which with propriety could have been litigated in the first suit[J” See also Restatement § 17. 10 The parties in Brent I and II are different so that the question arises whether master and ser

2012See, e.g., Montgomery Pres., Inc. v. Montgomery County Planning Bd., 424 Md. 367, 372 , 36 A.3d 419, 422 (2012). *140 The doctrine of res judicata “bars the relitigation of a claim if there is a final judgment in a previous litigation where the parties, the subject matter and causes of action are identical or substantially identical as to issues actually litigated and as to those which could have or should have been raised in the previous litigation.” R & D 2001, LLC v. Rice, 402 Md. 648, 663 , 938 A.2d 839, 848 (2008) (citations and quotation marks omitted); see also Anne Arundel County Bd. o

2012See, e.g., Montgomery Pres., Inc. v. Montgomery County Planning Bd., 424 Md. 367, 372 , 36 A.3d 419, 422 (2012). *140 The doctrine of res judicata “bars the relitigation of a claim if there is a final judgment in a previous litigation where the parties, the subject matter and causes of action are identical or substantially identical as to issues actually litigated and as to those which could have or should have been raised in the previous litigation.” R & D 2001, LLC v. Rice, 402 Md. 648, 663 , 938 A.2d 839, 848 (2008) (citations and quotation marks omitted); see also Anne Arundel County Bd. o

2004Thus, we have stated: “The functions of this doctrine, and the allied doctrine of res judicata, are to avoid the expense and vexation of multiple lawsuits, conserve judicial resources, and foster reliance on judicial action by minimizing the possibilities of inconsistent decisions.” Graham, supra, 315 Md. at 547, 555 A.2d at 504 , citing Montana v. United States, 440 U.S. 147, 153-54 , 99 S.Ct. 970, 973-74 , 59 L.Ed.2d 210, 217 (1979).

2004Thus, we have stated: “The functions of this doctrine, and the allied doctrine of res judicata, are to avoid the expense and vexation of multiple lawsuits, conserve judicial resources, and foster reliance on judicial action by minimizing the possibilities of inconsistent decisions.” Graham, supra, 315 Md. at 547, 555 A.2d at 504 , citing Montana v. United States, 440 U.S. 147, 153-54 , 99 S.Ct. 970, 973-74 , 59 L.Ed.2d 210, 217 (1979).

1991The Court of Appeals, in Pat Perusse Realty v. Lingo, 249 Md. 33, 45 , 238 A.2d 100 (1968), stated the public policy behind the doctrine of res judicata: Public policy against repetitive identical litigation, which underlies the rule of res judicata, applies here with logic and force to provide that Perusse’s rights were satisfied by having had its day in court on an issue, and that it is not entitled to another day in court against a particular defendant on that issue.

1991The Court of Appeals, in Pat Perusse Realty v. Lingo, 249 Md. 33, 45 , 238 A.2d 100 (1968), stated the public policy behind the doctrine of res judicata: Public policy against repetitive identical litigation, which underlies the rule of res judicata, applies here with logic and force to provide that Perusse’s rights were satisfied by having had its day in court on an issue, and that it is not entitled to another day in court against a particular defendant on that issue.

2017They assert that such cases, especially Whittle, 211 Md. 36 , 125 A.2d 41 , stand for the proposition that the Board, as an administrative body exercising quasi-judicial authority, could not reach a different conclusion on the viability of the License because “the facts and the law ... have remained unchanged since February 20, 2014.” Quoting Gaywood Community Ass’n, 246 Md. at 99-100 , 227 A.2d 735 , they state that their argument “rest[s] not strictly on the doctrine of res judicata, but upon the proposition that it would be arbitrary for the Board to arrive at opposite conclusions on substa

2017They assert that such cases, especially Whittle, 211 Md. 36 , 125 A.2d 41 , stand for the proposition that the Board, as an administrative body exercising quasi-judicial authority, could not reach a different conclusion on the viability of the License because “the facts and the law ... have remained unchanged since February 20, 2014.” Quoting Gaywood Community Ass’n, 246 Md. at 99-100 , 227 A.2d 735 , they state that their argument “rest[s] not strictly on the doctrine of res judicata, but upon the proposition that it would be arbitrary for the Board to arrive at opposite conclusions on substa

2003See Cook v. State, 281 Md. 665, 668 , 381 A.2d 671 , cert. denied, 439 U.S. 839 , 99 S.Ct. 126 , 58 L.Ed.2d 136 (1978). [UJnder the doctrine of res judicata, sometimes known as direct estoppel, a final and valid judgment rendered in one proceeding between two parties operates as a bar in a second proceeding between them on all matters that have been or could have been decided in the original litigation, where the second proceeding involves the same subject matter as the first cause of action.

2003See Cook v. State, 281 Md. 665, 668 , 381 A.2d 671 , cert. denied, 439 U.S. 839 , 99 S.Ct. 126 , 58 L.Ed.2d 136 (1978). [UJnder the doctrine of res judicata, sometimes known as direct estoppel, a final and valid judgment rendered in one proceeding between two parties operates as a bar in a second proceeding between them on all matters that have been or could have been decided in the original litigation, where the second proceeding involves the same subject matter as the first cause of action.

2012See, e.g., Montgomery Pres., Inc. v. Montgomery County Planning Bd., 424 Md. 367, 372 , 36 A.3d 419, 422 (2012). *140 The doctrine of res judicata “bars the relitigation of a claim if there is a final judgment in a previous litigation where the parties, the subject matter and causes of action are identical or substantially identical as to issues actually litigated and as to those which could have or should have been raised in the previous litigation.” R & D 2001, LLC v. Rice, 402 Md. 648, 663 , 938 A.2d 839, 848 (2008) (citations and quotation marks omitted); see also Anne Arundel County Bd. o

2012As we have previously described, the res judicata doctrine “embodies three elements: (1) the parties in the present litigation are the same or in privity with the parties to the earlier litigation; (2) the claim presented in the current action is identical to that determined or that which could have been raised and determined in the prior litigation; and (3) there was a final judgment on the merits in the prior litigation.” Rice, 402 Md. at 663 , 938 A.2d at 848 .

2011“Res judicata literally means ‘a thing adjudicated,’ and generally indicates ‘[a]n affirmative defense barring the same parties from litigating a second lawsuit on the same claim....’” Lizzi v. Washington Metropolitan Area, Transit Authority, 384 Md. 199, 206 , 862 A.2d 1017, 1022 (2004), quoting Black’s Law Dictionary 1336-37 (8th ed.2004).

2011“Res judicata literally means ‘a thing adjudicated,’ and generally indicates ‘[a]n affirmative defense barring the same parties from litigating a second lawsuit on the same claim....’” Lizzi v. Washington Metropolitan Area, Transit Authority, 384 Md. 199, 206 , 862 A.2d 1017, 1022 (2004), quoting Black’s Law Dictionary 1336-37 (8th ed.2004).

2017They assert that such cases, especially Whittle, 211 Md. 36 , 125 A.2d 41 , stand for the proposition that the Board, as an administrative body exercising quasi-judicial authority, could not reach a different conclusion on the viability of the License because “the facts and the law ... have remained unchanged since February 20, 2014.” Quoting Gaywood Community Ass’n, 246 Md. at 99-100 , 227 A.2d 735 , they state that their argument “rest[s] not strictly on the doctrine of res judicata, but upon the proposition that it would be arbitrary for the Board to arrive at opposite conclusions on substa

2017They assert that such cases, especially Whittle, 211 Md. 36 , 125 A.2d 41 , stand for the proposition that the Board, as an administrative body exercising quasi-judicial authority, could not reach a different conclusion on the viability of the License because “the facts and the law ... have remained unchanged since February 20, 2014.” Quoting Gaywood Community Ass’n, 246 Md. at 99-100 , 227 A.2d 735 , they state that their argument “rest[s] not strictly on the doctrine of res judicata, but upon the proposition that it would be arbitrary for the Board to arrive at opposite conclusions on substa

1975In Maryland the doctrine of res judicata, or estoppel by judgment, consists of two branches, direct estoppel by judgment and collateral estoppel by judgment. 6 Sterling v. Local 438, 207 Md. 132, 140 , 113 A. 2d 389, 393 , cert. denied, 350 U. S. 875 , 76 S. Ct. 119 (1955).

1975In Maryland the doctrine of res judicata, or estoppel by judgment, consists of two branches, direct estoppel by judgment and collateral estoppel by judgment. 6 Sterling v. Local 438, 207 Md. 132, 140 , 113 A. 2d 389, 393 , cert. denied, 350 U. S. 875 , 76 S. Ct. 119 (1955).

2012As we have previously described, the res judicata doctrine “embodies three elements: (1) the parties in the present litigation are the same or in privity with the parties to the earlier litigation; (2) the claim presented in the current action is identical to that determined or that which could have been raised and determined in the prior litigation; and (3) there was a final judgment on the merits in the prior litigation.” Rice, 402 Md. at 663 , 938 A.2d at 848 .

2012See, e.g., Montgomery Pres., Inc. v. Montgomery County Planning Bd., 424 Md. 367, 372 , 36 A.3d 419, 422 (2012). *140 The doctrine of res judicata “bars the relitigation of a claim if there is a final judgment in a previous litigation where the parties, the subject matter and causes of action are identical or substantially identical as to issues actually litigated and as to those which could have or should have been raised in the previous litigation.” R & D 2001, LLC v. Rice, 402 Md. 648, 663 , 938 A.2d 839, 848 (2008) (citations and quotation marks omitted); see also Anne Arundel County Bd. o

2003See Cook v. State, 281 Md. 665, 668 , 381 A.2d 671 , cert. denied, 439 U.S. 839 , 99 S.Ct. 126 , 58 L.Ed.2d 136 (1978). [UJnder the doctrine of res judicata, sometimes known as direct estoppel, a final and valid judgment rendered in one proceeding between two parties operates as a bar in a second proceeding between them on all matters that have been or could have been decided in the original litigation, where the second proceeding involves the same subject matter as the first cause of action.

1985In Cook v. State, 281 Md. 665, 668-69 , 381 A.2d 671 (1978), cert. denied, 439 U.S. 839 , 99 S.Ct. 126 , 58 L.Ed.2d 136 (1978), we said: [Ujnder the doctrine of res judicata, sometimes known as direct estoppel, a final and valid judgment rendered in one proceeding between two parties operates as a bar in a second proceeding between them on all matters that have been or could have been decided in the original litigation, where the second proceeding involves the same subject matter as the first cause of action____ ... [Ujnder the final adjudication rule, res judicata and collateral estoppel do n

2003See Cook v. State, 281 Md. 665, 668 , 381 A.2d 671 , cert. denied, 439 U.S. 839 , 99 S.Ct. 126 , 58 L.Ed.2d 136 (1978). [UJnder the doctrine of res judicata, sometimes known as direct estoppel, a final and valid judgment rendered in one proceeding between two parties operates as a bar in a second proceeding between them on all matters that have been or could have been decided in the original litigation, where the second proceeding involves the same subject matter as the first cause of action.

1985In Cook v. State, 281 Md. 665, 668-69 , 381 A.2d 671 (1978), cert. denied, 439 U.S. 839 , 99 S.Ct. 126 , 58 L.Ed.2d 136 (1978), we said: [Ujnder the doctrine of res judicata, sometimes known as direct estoppel, a final and valid judgment rendered in one proceeding between two parties operates as a bar in a second proceeding between them on all matters that have been or could have been decided in the original litigation, where the second proceeding involves the same subject matter as the first cause of action____ ... [Ujnder the final adjudication rule, res judicata and collateral estoppel do n

2003See Cook v. State, 281 Md. 665, 668 , 381 A.2d 671 , cert. denied, 439 U.S. 839 , 99 S.Ct. 126 , 58 L.Ed.2d 136 (1978). [UJnder the doctrine of res judicata, sometimes known as direct estoppel, a final and valid judgment rendered in one proceeding between two parties operates as a bar in a second proceeding between them on all matters that have been or could have been decided in the original litigation, where the second proceeding involves the same subject matter as the first cause of action.

1985In Cook v. State, 281 Md. 665, 668-69 , 381 A.2d 671 (1978), cert. denied, 439 U.S. 839 , 99 S.Ct. 126 , 58 L.Ed.2d 136 (1978), we said: [Ujnder the doctrine of res judicata, sometimes known as direct estoppel, a final and valid judgment rendered in one proceeding between two parties operates as a bar in a second proceeding between them on all matters that have been or could have been decided in the original litigation, where the second proceeding involves the same subject matter as the first cause of action____ ... [Ujnder the final adjudication rule, res judicata and collateral estoppel do n

2017In Powell v. Breslin, 430 Md. 52, 63-64 , 59 A.3d 531, 537-38 (2013), this Court described the doctrine of res judicata, or claim preclusion, as well as the circumstances that must be present for the doctrine to apply, stating: Res judicata is an affirmative defense that precludes the same parties from relitigating any suit based upon the same cause of action because the second suit involves a judgment that is conclusive, not only as to all matters that have been decided in the original suit, but as to all matters which with propriety could have been litigated in the first suit.

2017In Powell v. Breslin, 430 Md. 52, 63-64 , 59 A.3d 531, 537-38 (2013), this Court described the doctrine of res judicata, or claim preclusion, as well as the circumstances that must be present for the doctrine to apply, stating: Res judicata is an affirmative defense that precludes the same parties from relitigating any suit based upon the same cause of action because the second suit involves a judgment that is conclusive, not only as to all matters that have been decided in the original suit, but as to all matters which with propriety could have been litigated in the first suit.

2015Deciding as a matter of law that the “issue of negligence was [njeither litigated [n]or determined by [the trial court] in the debt action,” 5 the Court held that the trial court “was in error when [it] concluded that the Maryland counterclaim rule is compulsory and required that [Ms. Rowland] assert her malpractice claim in Harrison’s debt action or lose her right to litigate that matter under the doctrine of res judicata.” Id. at 230-31 , 577 A.2d 51 .

2015Deciding as a matter of law that the “issue of negligence was [njeither litigated [n]or determined by [the trial court] in the debt action,” 5 the Court held that the trial court “was in error when [it] concluded that the Maryland counterclaim rule is compulsory and required that [Ms. Rowland] assert her malpractice claim in Harrison’s debt action or lose her right to litigate that matter under the doctrine of res judicata.” Id. at 230-31 , 577 A.2d 51 .

2003We pointed out in Dixon, id. at 314, 604 A.2d 502 , that, “[a]s the Supreme Court' has previously held, the doctrine of res judicata must be applied to questions of jurisdiction in cases arising in state courts involving the application of the full faith and credit clause where, under the law of the state in which the original judgment was rendered, such adjudications are not susceptible to collateral attack.” See also Sherrer, 334 U.S. at 351-52 , 68 S.Ct. 1087 ; Jessica G. v. Hector M., 337 Md. 388, 404 , 653 A.2d 922 (1995) (“under the Maryland law of conflict of laws, the res judicata effe

2003We pointed out in Dixon, id. at 314, 604 A.2d 502 , that, “[a]s the Supreme Court' has previously held, the doctrine of res judicata must be applied to questions of jurisdiction in cases arising in state courts involving the application of the full faith and credit clause where, under the law of the state in which the original judgment was rendered, such adjudications are not susceptible to collateral attack.” See also Sherrer, 334 U.S. at 351-52 , 68 S.Ct. 1087 ; Jessica G. v. Hector M., 337 Md. 388, 404 , 653 A.2d 922 (1995) (“under the Maryland law of conflict of laws, the res judicata effe

2016Accord Tucker, supra, 35 Md.App. at 712 , 373 A.2d 16 (“If there has been a judicial determination that the court rendering a judgment has jurisdiction, the doctrine of res judicata applies and precludes a collateral attack upon that judgment.”). 7 .

2016Accord Tucker, supra, 35 Md.App. at 712 , 373 A.2d 16 (“If there has been a judicial determination that the court rendering a judgment has jurisdiction, the doctrine of res judicata applies and precludes a collateral attack upon that judgment.”). 7 .

2015Thus, although “the legal doctrine giving binding effect to decisions by zoning boards should not be fully equated with the doctrine of res judicata,” this Court has concluded that “[i]t is quite plain ... that at least some of the principles of the doctrine of res judicata are applicable to decisions by zoning boards.” Racine, 24 Md.App. at 450, 447 , 332 A.2d 306 .

2015Thus, although “the legal doctrine giving binding effect to decisions by zoning boards should not be fully equated with the doctrine of res judicata,” this Court has concluded that “[i]t is quite plain ... that at least some of the principles of the doctrine of res judicata are applicable to decisions by zoning boards.” Racine, 24 Md.App. at 450, 447 , 332 A.2d 306 .