transactional rule in Rhode Island

2026See id. at 276 (“[T]he claim extinguished includes all rights of [a party] to remedies against [another party] with respect to all or any part of the transaction, or series of connected transactions, out of which the [first] action arose.” (quoting Manego v. Orleans Board of Trade, 773 F.2d 1, 5 (1st Cir. 1985))); see also Goodrow v. Bank of America, N.A., 184 A.3d 1121, 1127 (R.I. 2018) (explaining that the transactional rule bars all claims “which could have properly been raised in a previous litigation” (quoting Bossian v. Anderson, 991 A.2d 1025, 1027 (R.I. 2010))).

2024This Court has explained that “the transactional rule provides that all claims arising from the same transaction or series of transactions - 13 - which could have properly been raised in a previous litigation are barred from a later action.” Bossian, 991 A.2d at 1027 (internal quotation marks omitted).

2026See id. at 276 (“[T]he claim extinguished includes all rights of [a party] to remedies against [another party] with respect to all or any part of the transaction, or series of connected transactions, out of which the [first] action arose.” (quoting Manego v. Orleans Board of Trade, 773 F.2d 1, 5 (1st Cir. 1985))); see also Goodrow v. Bank of America, N.A., 184 A.3d 1121, 1127 (R.I. 2018) (explaining that the transactional rule bars all claims “which could have properly been raised in a previous litigation” (quoting Bossian v. Anderson, 991 A.2d 1025, 1027 (R.I. 2010))).

2008The defendants rely principally on El Gabri v. Lekas as support for their interpretation of the transactional rule. 681 A.2d 271 , 277 (R.I. 1996).

2026See id. at 276 (“[T]he claim extinguished includes all rights of [a party] to remedies against [another party] with respect to all or any part of the transaction, or series of connected transactions, out of which the [first] action arose.” (quoting Manego v. Orleans Board of Trade, 773 F.2d 1, 5 (1st Cir. 1985))); see also Goodrow v. Bank of America, N.A., 184 A.3d 1121, 1127 (R.I. 2018) (explaining that the transactional rule bars all claims “which could have properly been raised in a previous litigation” (quoting Bossian v. Anderson, 991 A.2d 1025, 1027 (R.I. 2010))).

2020With respect to the identity of issues prong, “this Court has adopted the transactional rule governing the preclusive effect of the doctrine of res judicata.” Id. at 178 (brackets omitted) (quoting Goodrow, 184 A.3d at 1127 ).

2026To determine “the scope of the issues to be precluded in the second action, we have adopted the broad transactional rule.” Town of Warren v. Bristol Warren Regional School District, 159 A.3d 1029, 1036 (R.I. 2017) (quoting Ritter v. Mantissa Investment Corp., 864 A.2d 601, 605 (R.I. 2005)).

2019"What constitutes a transaction or a series of connected transactions is to be determined pragmatically, giving weight to such considerations as whether the facts are related in time, space, origin, or motivation, whether they form a convenient trial unit, and whether their treatment as a unit conforms to the parties' expectations." Id. (deletion omitted) (quoting Town of Warren v. Bristol Warren Regional School District , 159 A.3d 1029 , 1036 (R.I. 2017) ).

2018"The transactional rule provides that 'all claims arising from the same transaction or series of transactions which could have properly been raised in a previous litigation are barred from a later action.' " Id. (quoting DiBattista , 808 A.2d at 1086 ).

2018In this case, there is no claim that res judicata fails for want of identity of parties; therefore, we need not address that factor here and instead focus only on whether an identity of the issues and a final judgment on the merits exist. 1 Identity of Issues "An identity of issues requires 'first, [that] the issue sought to be precluded must be identical to the issue decided in the prior proceeding; second, the issue must actually [have been] litigated; and third, the issue must necessarily have been decided.' " State v. Pacheco , 161 A.3d 1166 , 1173 (R.I. 2017) (quoting State v. Godette , 7

2026To determine “the scope of the issues to be precluded in the second action, we have adopted the broad transactional rule.” Town of Warren v. Bristol Warren Regional School District, 159 A.3d 1029, 1036 (R.I. 2017) (quoting Ritter v. Mantissa Investment Corp., 864 A.2d 601, 605 (R.I. 2005)).

2026“This rule precludes the re-litigation of all or any part of the transaction, or series of connected transactions, out of which the first action arose.” Id. (brackets omitted) (quoting Ritter, 864 A.2d at 605 ).

2019Furthermore, "[t]his Court has adopted the transactional rule governing the preclusive effect of the doctrine of res judicata ." Id. (deletion omitted) (quoting Bossian v. Anderson , 991 A.2d 1025 , 1027 (R.I. 2010) ).

2018In this case, there is no claim that res judicata fails for want of identity of parties; therefore, we need not address that factor here and instead focus only on whether an identity of the issues and a final judgment on the merits exist. 1 Identity of Issues "An identity of issues requires 'first, [that] the issue sought to be precluded must be identical to the issue decided in the prior proceeding; second, the issue must actually [have been] litigated; and third, the issue must necessarily have been decided.' " State v. Pacheco , 161 A.3d 1166 , 1173 (R.I. 2017) (quoting State v. Godette , 7

2014See Plunkett v. State, 869 A.2d 1185, 1188-89 (R.I.2005) (citing ElGabri v. Lekas, 681 A.2d 271, 276 (R.I.1996)).

2011In Plunkett v. State , our Supreme Court adopted the Restatement (Second) of Judgments definition of the transactional rule: "(2) What factual grouping constitutes a `transaction'[] and what groupings constitutes a `series'[] are to be determined pragmatically, giving weight to such considerations as whether the facts are related in time, space, origin, or motivation, whether they *Page 6 form a convenient trial unit, and whether their treatment as a unit conforms to the parties' expectations or business understanding or usage ." 869 A.2d 1185 , 1188-89 (R.I. 2005) (quoting Restatement (Second

2026See id. at 276 (“[T]he claim extinguished includes all rights of [a party] to remedies against [another party] with respect to all or any part of the transaction, or series of connected transactions, out of which the [first] action arose.” (quoting Manego v. Orleans Board of Trade, 773 F.2d 1, 5 (1st Cir. 1985))); see also Goodrow v. Bank of America, N.A., 184 A.3d 1121, 1127 (R.I. 2018) (explaining that the transactional rule bars all claims “which could have properly been raised in a previous litigation” (quoting Bossian v. Anderson, 991 A.2d 1025, 1027 (R.I. 2010))).

2026See id. at 276 (“[T]he claim extinguished includes all rights of [a party] to remedies against [another party] with respect to all or any part of the transaction, or series of connected transactions, out of which the [first] action arose.” (quoting Manego v. Orleans Board of Trade, 773 F.2d 1, 5 (1st Cir. 1985))); see also Goodrow v. Bank of America, N.A., 184 A.3d 1121, 1127 (R.I. 2018) (explaining that the transactional rule bars all claims “which could have properly been raised in a previous litigation” (quoting Bossian v. Anderson, 991 A.2d 1025, 1027 (R.I. 2010))).

2026See Reynolds, 81 A.3d at 1115 .

2018In this case, there is no claim that res judicata fails for want of identity of parties; therefore, we need not address that factor here and instead focus only on whether an identity of the issues and a final judgment on the merits exist. 1 Identity of Issues “An identity of issues requires ‘first, [that] the issue sought to be precluded must be identical to the issue decided in the prior proceeding; second, the issue must actually [have been] litigated; and third, the issue must necessarily have been decided.’” State v. Pacheco, 161 A.3d 1166, 1173 (R.I. 2017) (quoting State v. Godette, 751 A

2018In this case, there is no claim that res judicata fails for want of identity of parties; therefore, we need not address that factor here and instead focus only on whether an identity of the issues and a final judgment on the merits exist. 1 Identity of Issues "An identity of issues requires 'first, [that] the issue sought to be precluded must be identical to the issue decided in the prior proceeding; second, the issue must actually [have been] litigated; and third, the issue must necessarily have been decided.' " State v. Pacheco , 161 A.3d 1166 , 1173 (R.I. 2017) (quoting State v. Godette , 7

2010The transactional rule provides that “all claims arising from the same transaction or series of transactions which could have properly been raised in a previous litigation are barred from a later action.” DiBattista, 808 A.2d at 1086 ; see also Mills v. Toselli, 916 A.2d 756, 757 (R.I.2006) (mem.); see generally Foster-Glocester Regional School Committee v. Board of Review, Department of Labor and Training, 854 A.2d 1008 , 1014 n. 2 (R.I.2004); Thomas v. Ross, 477 A.2d 950, 953 (R.I.1984) (“Trial on an installment-plan basis cannot be countenanced * * *.”).

2010The transactional rule provides that “all claims arising from the same transaction or series of transactions which could have properly been raised in a previous litigation are barred from a later action.” DiBattista, 808 A.2d at 1086 ; see also Mills v. Toselli, 916 A.2d 756, 757 (R.I.2006) (mem.); see generally Foster-Glocester Regional School Committee v. Board of Review, Department of Labor and Training, 854 A.2d 1008 , 1014 n. 2 (R.I.2004); Thomas v. Ross, 477 A.2d 950, 953 (R.I.1984) (“Trial on an installment-plan basis cannot be countenanced * * *.”).

2010The transactional rule provides that “all claims arising from the same transaction or series of transactions which could have properly been raised in a previous litigation are barred from a later action.” DiBattista, 808 A.2d at 1086 ; see also Mills v. Toselli, 916 A.2d 756, 757 (R.I.2006) (mem.); see generally Foster-Glocester Regional School Committee v. Board of Review, Department of Labor and Training, 854 A.2d 1008 , 1014 n. 2 (R.I.2004); Thomas v. Ross, 477 A.2d 950, 953 (R.I.1984) (“Trial on an installment-plan basis cannot be countenanced * * *.”).

1997RESTATEMENT (SECOND) OF JUDGMENTS , §§ 24, 25 (1982); Gonsalves v. Alpine Country Club , 563 F. Supp. 1283, 1287 (D.R.I. 1983), aff'd , 727 F.2d 27 (1st Cir. 1984).