preclusive effect doctrine in Rhode Island

2026“Privity exists where there is a commonality of interests such that one party adequately represents the other’s interests.” Mallozzi v. Warwick Wings, LLC, 330 A.3d 557 , 569 (R.I. 2025) (quoting Huntley v. State, 63 A.3d 526, 531 (R.I. 2013)). -6- As to the identity of the issues element, “this Court has adopted the ‘transactional’ rule governing the preclusive effect of the doctrine of res judicata.” Bossian, 991 A.2d at 1027 (deletion omitted) (quoting DiBattista v. State, 808 A.2d 1081, 1086 (R.I. 2002)).

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

2026“Privity exists where there is a commonality of interests such that one party adequately represents the other’s interests.” Mallozzi v. Warwick Wings, LLC, 330 A.3d 557 , 569 (R.I. 2025) (quoting Huntley v. State, 63 A.3d 526, 531 (R.I. 2013)). -6- As to the identity of the issues element, “this Court has adopted the ‘transactional’ rule governing the preclusive effect of the doctrine of res judicata.” Bossian, 991 A.2d at 1027 (deletion omitted) (quoting DiBattista v. State, 808 A.2d 1081, 1086 (R.I. 2002)).

2019Second, "[t]his Court has adopted the transactional rule governing the preclusive effect of the doctrine of res judicata ." Goodrow , 184 A.3d at 1127 (deletion omitted) (quoting Bossian v. Anderson , 991 A.2d 1025 , 1027 (R.I. 2010) ).

2020Although no final judgment has entered in that case, the sale of the marina in that proceeding was an interlocutory order concerning the sale of -8- “[T]his Court has adopted the transactional rule governing the preclusive effect of the doctrine of res judicata.” Seaport Studios, Inc., 212 A.3d at 178 (quoting Goodrow, 184 A.3d at 1127 ).

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 ).

2026“In accordance with that rule, res judicata ‘precludes the relitigation of all or any part of the transaction, or series of connected transactions, out of which the first action arose.’” Reynolds, 81 A.3d at 1116 (brackets omitted) (quoting Lennon v. Dacomed Corp., 901 A.2d 582, 592 (R.I. 2006)).

2011To determine the remaining element, identity of issues, Rhode Island courts use the "`transactional rule governing the preclusive effect of the doctrine of res judicata * * *.'" Id. (omission in original) (quoting DiBattista v. State , 808 A.2d 1081 , 1086 (R.I. 2002)) (citing Lennon v. Dacomend Corp. , 901 A.2d 582 , 592 (R.I. 2006); Ritter v. Mantissa Inv.

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

2008Furthermore, our Supreme Court has noted that this jurisdiction has adopted "the `transactional' rule governing the preclusive effect of the doctrine of res judicata." Duffy v. Milder , 896 A.2d 27 , 35 (R.I. 2006) (quoting DiBattista v. State , 808 A.2d 1081 , 1086 (R.I. 2002)), in *Page 4 which "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. at 35-36.

2006We note that this jurisdiction has adopted “the ‘transactional’ rule governing the preclusive effect of the doctrine of res judieata[,]” Duffy v. Milder, 896 A.2d 27, 35 (R.I.2006) (quoting DiBattista v. State, 808 A.2d 1081, 1086 (R.I.2002)), in which “‘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. at 35-36.

2026“Privity exists where there is a commonality of interests such that one party adequately represents the other’s interests.” Mallozzi v. Warwick Wings, LLC, 330 A.3d 557 , 569 (R.I. 2025) (quoting Huntley v. State, 63 A.3d 526, 531 (R.I. 2013)). -6- As to the identity of the issues element, “this Court has adopted the ‘transactional’ rule governing the preclusive effect of the doctrine of res judicata.” Bossian, 991 A.2d at 1027 (deletion omitted) (quoting DiBattista v. State, 808 A.2d 1081, 1086 (R.I. 2002)).

2026“In accordance with that rule, res judicata ‘precludes the relitigation of all or any part of the transaction, or series of connected transactions, out of which the first action arose.’” Reynolds, 81 A.3d at 1116 (brackets omitted) (quoting Lennon v. Dacomed Corp., 901 A.2d 582, 592 (R.I. 2006)).

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

2002See ElGabri, 681 A.2d at 276 .